DSA transparency report

About this report

EuroClinics publishes a transparency report twice yearly under Article 15 of Regulation (EU) 2022/2065 (Digital Services Act).

Period covered: 2026-01-01 to 2026-06-30. Next report: 2027-01-15.

Orders from member-state authorities

DSA Art. 9 (orders to act against illegal content): 0 received in this period.

DSA Art. 10 (orders to provide information): 0 received in this period.

Content-moderation notices

Notices received (DSA Art. 16): 12.

Categories: 7 about review authenticity, 3 about misleading treatment claims, 2 about identifiable patient images without consent.

Actions taken: 9 removals, 2 ranking demotions, 1 no-action (notice unfounded).

Median time to decision: 36 hours.

Own-initiative moderation

Automated detection: weekly run of a heuristic checker (review-velocity anomalies, copy-paste pattern, IP clustering) plus a language model classifier for hate speech.

Removals after own-initiative review: 31 — 18 fake reviews, 8 unsubstantiated treatment claims, 5 promotional content.

Human reviewers: 2 full-time, EN/ES/DE/FR/IT/PT/NL/TR coverage. All escalations reviewed by a senior moderator before action.

Internal complaints (DSA Art. 20)

Appeals received: 4 — 3 review-removal challenges, 1 listing suspension.

Outcomes: 1 reinstated, 3 original decision upheld with additional explanation.

Median time to resolution: 11 days.

Resources dedicated to content moderation

Trust & Safety team: 2 FTE moderators, 1 part-time policy lead, 1 fractional legal counsel.

Languages with native-speaker coverage: EN, ES, DE, FR, IT, PT, NL, TR.

Annual training: 24 hours per moderator on DSA, GDPR, and healthcare-specific moderation (medical-claims policy, scope-of-practice issues).

Methodology

Source data: internal moderation ledger (every action timestamped + reasoned), notice form submissions, appeal submissions.

Data freshness: end-of-period plus 14-day reconciliation window.

Independent review: figures reviewed by external counsel before publication.