SME Developers Seek Clarification on DSA: A Call for Dialogue and Enhanced Protections

As the digital landscape continues to evolve, micro, small, and medium-sized enterprise (MSME) developers find themselves at a crucial juncture, navigating the complexities of the Digital Services Act (DSA). While the DSA aims to foster a safer and more reliable online environment, the MSME members of ACT | The App Association ask the European Commission (EC) for clearer guidelines and protections to ensure compliance does not inadvertently expose them to new risks.

MSME perspective

Our members, the driving force behind tech innovation, are deeply invested in creating and building on trustworthy, secure, user-centric online platforms. The DSA’s current trajectory raises concerns, particularly around the definitions and obligations it imposes on ‘traders’ and the potential for misuse of publicly disclosed data. In response, we’ve reached out to the European Commission with a plea for clear guidance and robust protections. Our letter underscores the need for:

1. Clarity on ‘trader’ definition: The DSA should precisely define what constitutes a ‘trader’ to avoid any ambiguity that could hinder MSME operations.
2. Protection against data misuse: With the requirement for traders to disclose contact information, there’s a real risk that MSMEs could become targets for automated attacks and scams. We advocate for mechanisms that prevent the misuse of this data, ensuring that compliance doesn’t compromise security.
3. Exempting MSMEs from DSA Article 30 trader obligations: Clarify that the DSA’s exemption for MSME online platforms extends to traders to account for the disproportionate burdens of transparency reporting obligations on MSMEs.

Moving forward

Our members’ call for clarity and protection underlines the broader need for a regulatory framework that supports innovation while ensuring user trust and safety. As MSMEs continue to drive forward the digital economy, their ability to operate effectively and securely under the DSA is paramount. As MSME developers continue to navigate the DSA’s requirements, their proactive engagement with the European Commission represents a vital step toward ensuring that the act supports rather than hinders the growth and security of the digital marketplace.

You can read the full letter outlining our members’ detailed concerns below or at the link here.