Statutory data holders responsible for implementing qualifying access requests
DSA designated VLOP/VLOSE data-provider role
This role covers providers of services designated as very large online platforms or very large online search engines under the EU Digital Services Act. Such providers hold data needed for research into systemic risks and bear access duties under Article 40.
Two access channels and a bounded challenge process
For vetted research, the provider must supply access under the coordinator's reasoned request and its timetable. It can seek amendment on specified grounds within 15 days and must offer alternatives; the coordinator then decides within 15 days. Mediation is possible after that decision, but does not automatically displace it. Article 40(12) separately requires qualifying researchers' access to public data without undue delay. Actual provision or termination must be notified to the coordinator within three working days, distinguishing permission from fulfilment.
DSA designated VLOP/VLOSE data-provider role → Vetted researchers — project-specific role
must provide access under a reasoned request
Data and appropriate interface follow the request within its reasonable period. Standard-tool/data-management restrictions that hinder research require explicit request provision; no additional personal-data conditions outside request.
DSA designated VLOP/VLOSE data-provider role → Provider-establishment Digital Services Coordinator
may seek mediation after an amendment decision
Provider may request within5working days and bears costs. DSC participation is optional, judicial rights preserved; no agreement leaves last DSC decision valid. No mediation exercise acquired.
DSA designated VLOP/VLOSE data-provider role → Provider-establishment Digital Services Coordinator
may request amendment on specified access or security grounds
Provider has15days after receipt and must propose alternatives; DSC decides within15days. Additional information does not displace that decision deadline.
DSA designated VLOP/VLOSE data-provider role → Public-data researchers under40(12)
must give qualifying researchers public-data access without undue delay
40(12) imports40(8)(b)–(e), including funding disclosure and proportionality, for systemic-risk research. It is separate from paragraph4 project vetting.
Data and appropriate interface follow the request within its reasonable period. Standard-tool/data-management restrictions that hinder research require explicit request provision; no additional personal-data conditions outside request.
Provider has15days after receipt and must propose alternatives; DSC decides within15days. Additional information does not displace that decision deadline.
Provider may request within5working days and bears costs. DSC participation is optional, judicial rights preserved; no agreement leaves last DSC decision valid. No mediation exercise acquired.
40(12) imports40(8)(b)–(e), including funding disclosure and proportionality, for systemic-risk research. It is separate from paragraph4 project vetting.