Civil society urges human rights focus for DSA enforcement

According to EDRi, on February 18, 2026 the DSA Human Rights Alliance published a set of eight principles titled "Principles for a Human Rights-Centred Application of the DSA: A Global Perspective." Thirty civil society organisations, researchers, and independent experts signed the document, calling for enforcement that centres human rights, enables cross-border participation, and empowers diverse stakeholders to engage in enforcement and strategic litigation under the Digital Services Act.

What the Alliance wants

The principles ask regulators and the European Commission to design DSA enforcement with inclusion and rights protections built into procedures, not added later. Core asks include making trusted flagger arrangements open and accountable, ensuring systemic risk due diligence considers cross-border and regional differences, and enabling civil society from inside and outside the EU to participate in oversight and litigation. The Alliance frames this work as a continuation of the GDPR's Brussels Effect, arguing that how the DSA is applied will travel beyond EU borders and reshape platform practice globally.

If regulators adopt the Alliance's recommendations, platforms will face enforcement expectations that go beyond technical compliance and into procedural fairness, transparency, and meaningful participation. That raises compliance complexity for EU technology firms and international platforms operating in the bloc, because enforcement design will determine how obligations such as content moderation, data access for investigations, and transparency reporting are actually carried out. The Alliance also highlights the risk that harmonisation, if done without inclusive input, could unintentionally weaken procedural protections for open source and marginalised groups.

Why This Matters

The Alliance directly links enforcement design to concrete DSA mechanisms such as trusted flagger procedures and systemic risk assessments, which affects how content moderation and platform accountability are implemented. For teams weighing US versus EU tools, this means platforms hosted in the EU or run by EU providers may offer stronger procedural transparency and clearer pathways for civil society oversight, but they may also be subject to broader cross-border takedown and reporting duties. Multiple observers have compared this dynamic to the GDPR era, and this marks a sustained effort to ensure that the DSA's extra-territorial effects do not exclude non-EU voices from shaping enforcement.

What You Should Do: read the Alliance's eight principles, follow incoming Commission guidance, and press national regulators to include non-EU civil society in consultations. Platform operators should review their trusted flagger workflows and systemic risk processes now, and compliance teams should factor potential cross-border enforcement into contractual and operational plans. Civil society groups outside the EU should use the consultation window to get on record concerns about procedural safeguards.

Watch for uptake of the principles in European Commission guidance, the design of trusted flagger lists, national regulator procedures in candidate states, and strategic litigation that tests inclusion and cross-border enforcement over the next 6 to 12 months.

Sources

EDRi, DSA Human Rights Alliance guidelines, https://edri.org/our-work/ensuring-human-rights-based-global-perspectives-in-the-dsa-enforcement-the-dsa-human-rights-alliances-guidelines/

Element, "The Digital Omnibus: Opportunities and risks for open source", https://element.io/blog/the-digital-omnibus-opportunities-and-risks-for-open-source/

Nikola K, "An EU citizen's GDPR audit", https://nikolak.com/gdpr-failure/

noyb, "EU-US data transfers: time to prepare, more trouble to come", https://noyb.eu/en/eu-us-data-transfers-time-prepare-more-trouble-come