Meeting with
Go
le and Alphabet
Ref. Ares(2022)2869279 - 09/04/2022
Ref. Ares(2022)5039270 - 11/07/2022
Brussels, 30 March 2022
Digital Services Act
Main messages
The Digital Services Act is almost in the final phase of negotiation. Depending on the
exact timeline for application, companies like Google would soon have to comply with
greater responsibilities, which consequently requires greater due diligence obligations.
This all comes with scale and public outreach, and corresponds with what the largest
digital companies called for.
In this regard, I would expect you to be ready to comply with all the due diligence
obligations as set in the DSA, possibly even earlier than the given date of application.
Concretely, you might know that the DSA will set rules on content moderation practices
of online platforms, and its interaction with freedom of speech and healthy and well-
informed public debate.
Under these rules, platforms would also have to apply effective measures against
misuse of their systems and transparency mechanisms. Users will have the right to be
informed about the moderation policies and decisions by the platform, to contest them
and the necessary means of redress.
For very large platforms, this is taken one step further, to ensure that those ‘public
spaces’ are open and fair: they wil need to assess and address risks that their systems
pose to freedom of expression and other fundamental rights.
Defensive
Does the Commission support a ban, phase out or more transparency requirements
for targeting advertising in the DSA?
We welcome the discussion on advertising and recognise that this is a complex area
with multi-faceted concerns.
The advertising system is at the centre of some of the societal risks addressed in the
DSA, this is not only limited to micro-targeting: illegal ads or misuse of the system for
manipulation (e.g. political ads); on specific platforms, financial incentive for users to
publish illegal content and monetise it (platform-specific, not everywhere).
For micro-targeting, there are wider issues as well, e.g. protection of personal data and
privacy; specific behaviour of advertisers (not the intermediary), e.g. political campaigns,
or publishers, e.g. ad fraud; risks of collusion in ad bidding and price setting
transparency, etc.
And benefits: regional parties reach their electorate; possible for small sellers to reach
consumers (e.g. local producer); NGOs disseminating messages for participation in
civil society.
The DSA addresses some of these issues when they are specific to the risks pursued
by the intervention and to platforms. Measures will follow several objectives:
it is crucial that users have all the information they need to have informed opinions
and clear understanding of advertising on platforms;
burden cannot fall on users alone to enforce their rights. It is important to have
measures for public scrutiny and accountability – in particular, a special regime for
very large platforms, where the impacts are the strongest. They need to manage
risks posed by their systems.
Topics for discussion
1/2
Meeting with
Google and Alphabet
Brussels, 30 March 2022
Background
The position paper of DOT Europe, an association representing in majority very large
online platforms including Google, from March 2022 (i.e. prior to the trilogue negotiations
and especially in reaction to the Parliament’s position), raises the following points:
Contact – briefing contribution:
1 These are deceptive practices on user interfaces that trick users into doing things they might not
otherwise do. Both co-legislators have provisions for dark patterns in their mandate but the
Parliament’s text is broader, covering more services (including technical intermediaries) and more
types of practices.
Topics for discussion
2/2
