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Know your business – 5 obligations relating to the Digital Services Act



Effective from February 17, 2024, the European Digital Services Act (DSA) regulates the obligations of digital services, including host providers, online marketplaces, and social media networks, who are intermediaries connecting customers with goods, services, and content.

This is a wide-remit which includes very large global platforms that provide services used by millions of people across the world each day and that bring together the online offerings of thousands of third-party suppliers.

The risk factors to be considered and managed are significant and know your business (KYB) processes, including supplier due diligence and risk management come to the fore.




The aims of the act

The DSA aims to build a safer and fairer online world. It introduces rules that protect users in the European Union in regards to illegal goods, content, and services, as part of their fundamental rights. 

Its six core pillars are to deliver:

  • A simpler way to report illegal content, goods, or services
  • Stronger protections for people targeted by online harassment and bullying
  • Further transparency around advertising
  • Bans on certain types of targeted advertising, such as those using sensitive data or the data of minors
  • Easy-to-use and free-of-charge complaints mechanisms
  • Simplified terms and conditions



Who does it apply to?

The DSA applies to very large online platforms, marketplaces, social media, and search engines. Average users will exceed 10% of the EU’s population, equivalent to having 45 million or more users.

Digital service providers operating in the EU will need to identify and clarify who is selling products or offering services via their platform. There is a requirement to “trace their traders”, which Moody’s calls know your business or KYB.

This KYB process ensures a safe, transparent, and trustworthy environment for consumers; discourages traders who abuse platforms by selling unsafe or counterfeit goods; and protects digital service providers from reputational damage, while achieving compliance.

The new KYB obligations mean providers must obtain and verify key information from traders/third parties selling products or offering services via their platform. This information includes:

  • Name and contact details, such as address, telephone number and e-mail address
  • A copy of the identification document or any other electronic identification as defined in article 3 of the regulation
  • Where the trader is registered in a trade register or similar public register, the trade register in which the trader is registered and its registration number or equivalent means of identification in that register
  • A self-certification by the trader committing to offer products or services that comply with the EU law

Moody’s can provide an integrated solution to deliver this KYB requirement with access to company data and public registries of information. This supports the identification and verification of business customers who may be trading on a digital platform. 




Obligations for intermediaries

There are several obligations for intermediaries who provide digital services to comply with. Each obligation requires the platform provider to know the business they are dealing with, so they can understand potential risks, establish trust, and make decisions with confidence about who they allow to trade on their platform.

Here are five compliance requirements to consider:

  1. Prevent abuse of systems
    Platforms must mitigate against risks such as disinformation or election manipulation, cyber violence against women, or harms to minors online by taking risk-based action, including oversight through independent audits of risk management measures.

  2. New rules to trace sellers in online marketplaces
    To help build consumer trust and prevent scammers there are to be sustained efforts to enhance the traceability of products using technology. There is a new obligation for online marketplaces to randomly check existing databases to understand if products or services offered through their sites are compliant.

  3. A ban on “dark patterns”
    This refers to a ban on businesses and their customers/traders/third parties using misleading tricks that manipulate users into making choices they do not intend to make. It’s therefore important to gain a risk profile for any business before onboarding, and to monitor counterparties that have been onboarded.

  4. Measures to counter illegal content online, including illegal goods and services
    The DSA imposes a requirement for new mechanisms that allow users to flag illegal content online, and for platforms to cooperate with specialist “trusted flaggers” to identify and remove illegal content. Mitigation of this risk involves understanding who may pose a risk of being involved or implicated in producing illegal content to prevent them gaining access to platforms.

  5. New obligations for the protection of minors on any platform in the EU
    This includes a ban on targeted advertising on online platforms through the profiling of children. There are also rules based on special categories of personal data such as ethnicity, political views or sexual orientation.



Summary

The overarching goal of the DSA is to foster safer online environments. Under the new rules, online platforms must implement ways to prevent and remove illegal goods, services, or content while simultaneously giving users the means to report issues and lodge complaints.

Additionally, the DSA bans targeted advertising based on a person’s sexual orientation, religion, ethnicity, or political beliefs and puts restrictions on targeted advertising to children. It also requires online platforms to provide more transparency on how their algorithms work.

Online platforms that qualify as online marketplaces are subject to a know your business obligation, which means that they must verify the identity of traders who use their platform to sell products and services to consumers.

For traders, it is important to keep in mind they are responsible for the accuracy of the information that now needs to be provided to the digital service provider. On the other hand, providers of online marketplaces need to understand this obligation applies to new traders on their platform, as well as traders who are already active.

Regarding active traders - those who have already been onboarded – digital service providers must use reasonable efforts to verify them within 12 months of the DSA’s introduction. If the trader does not correct or complete their information, the provider must promptly suspend the provision of services until the KYB obligations are met.




How Moody’s can help

Moody’s offers automated KYB workflows, integrated with leading sources of business data, to help any digital service provider build a picture of risk. We make it easier to identify and verify traders and sellers in the EU and beyond.

A KYB process can be applied when onboarding new traders or third parties, and for ongoing risk monitoring. With a holistic and risk-based approach, we can help digital service providers understand counterparty risk to make decisions with confidence about who to work with.

If you would like to know more about KYB automation and our risk screening solutions, please get in touch anytime – we would love to hear from you.