DSA Content Moderation Reporting + Statements of Reasons Requirements

Hello,

We’re currently in the trenches of DSA compliance. Part of this involves looking at our use of Discourse, as our discussion board qualifies as an “online platform” under the DSA.

As you may know, there is now a standardised Content Moderation Transparency Report, which removes any flexibility we had previously. An additional requirement on top of this is to submit applicable Statements of Reasons to the DSA Transparency Database, and we’ve run into some limitations with the moderation abilities in Discourse.

In particular, we need to be able to consistently record structured information alongside moderation decisions:

  • Expanded, custom suspension reasons, which we can align with the DSA’s standardised taxonomy. It’s currently not possible to add additional suspension reasons, rather than renaming the existing predefined reasons
  • Whether the decision relates to illegal content or a Terms & Conditions violation
  • The contractual basis for the decision
  • The information source (user report, own-initiative moderation, Trusted Flagger, etc.)

It doesn’t seem possible to configure custom dropdowns within the suspension UI to capture this information, but please correct me if I’m mistaken. We can provide additional information through the “Email Message” field, but this doesn’t feel like a viable long-term solution, as it puts a lot of responsibility on our moderators and doesn’t give us the structured data we yearn for.

I’d be really interested to know how other EU customers (and Discourse themselves?) are approaching the standardised DSA reporting + Statement of Reasons requirements, and whether any additional functionality in this area is planned. We really don’t want to move away from Discourse, so I hope we can work something out - any advice appreciated!

Hey—thanks for your questions. I admit that I was not aware of the new standardised reporting—we are still using Digital Services Act 2025 (DSA) Transparency Report | Discourse - Civilized Discussion.

I did some digging and it does look like we are in scope to use this horrific template. Let me do some due diligence with our lawyer and I’ll come back to you.

Annex_I__Transparency_reports_templates_ME0vKI0A1K5vzNvP3VciJ7y26R4_109690.xlsx (85.3 KB)