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EU DSA · EU-DSA-ART37-COMPLIANCE-OFFICER

EU DSA Article 41 - Compliance function (VLOPs and VLOSEs)

Establish an independent compliance function with sufficient authority, stature, resources, and management body access to monitor DSA compliance

CRITICALRequirementGovernanceBinding regulationIn forceApplies from 17 February 2024

Where this comes from

Provision: Article 41 - Compliance function (VLOPs and VLOSEs)

Instrument: EU Digital Services Act (Regulation 2022/2065)

Citation: Regulation (EU) 2022/2065 of the European Parliament and of the Council, Article 41

Text version: Regulation (EU) 2022/2065 (DSA), OJ L 277, 27.10.2022

Read the official text ↗

Who it applies to

It applies when all of these are true:

  • Service is a Very Large Online Platform/Search Engine (45M+ EU users)
  • Service has users in the European Union

What engineering work it implies

Sample acceptance criteria Landfall generates for this obligation:

  • Implementation or documented process meets the reviewed acceptance criteria; identify the tested version and deployment status separately
  • Configure defaults from the assessed source and purpose; do not enable data collection or processing merely because this task exists
  • Validate behavior for the assessed actors and use cases, including applicable guest or administrator paths
  • UI clearly communicates what the feature does to users
  • API returns appropriate error codes when feature blocks an action

Questions people ask

Does EU DSA Article 41 - Compliance function (VLOPs and VLOSEs) apply to my service?
It applies when Service is a Very Large Online Platform/Search Engine (45M+ EU users); Service has users in the European Union.
From when does this apply?
EU DSA Article 41 - Compliance function (VLOPs and VLOSEs) applies from 17 February 2024. Its current status is: in force.

Find out whether this one lands on you

Landfall's pre-scan answers the applicability question above for your product in minutes, then turns every obligation that applies into traceable engineering tickets with a citation chain your auditors can follow.

Run the pre-scanAll EU DSA obligations

Not legal advice. Landfall maps regulatory obligations to engineering work for planning purposes. Its verdicts are not legal advice and create no attorney-client relationship — verify with qualified counsel before relying on them.

What Landfall Is NOT

Critical Boundaries

Understanding these boundaries is essential before using this product. Misuse of this tool for purposes outside its scope may create legal, regulatory, or commercial risk for your organization.

NOT Legal Advice

This product does not provide legal advice and does not create an attorney-client relationship.

Interpretations are informational analysis, not legal counsel. Always consult qualified legal professionals for compliance decisions.

NOT a Risk Score

We do not quantify, calculate, or certify your compliance risk level.

No numerical risk rating, compliance percentage, or safety score. Risk assessment requires human judgment about your specific context.

NOT Runtime Enforcement

This is a planning and mapping tool, not a runtime enforcement system.

Does not integrate with your production systems. Does not block, filter, or enforce compliance in real-time. Implementation is your responsibility.

NOT Regulatory Approval

Using this tool does not mean you are compliant with any regulation.

No certification, seal of approval, or compliance guarantee. Regulators will evaluate your actual implementation, not your use of this tool.

NOT Authoritative Interpretation

Our interpretations are not binding and may differ from regulatory guidance.

Only regulators and courts provide authoritative interpretation. Our analysis reflects our reading of requirements, which may be incomplete or incorrect.

NOT a Safe Harbor

This tool does not shield you from enforcement actions or liability.

Documentation of your process is valuable, but does not constitute a legal defense. Compliance is ultimately your organization's responsibility.

NOT an AI Compliance Agent

AI features assist analysis but do not make compliance decisions for you.

AI-generated interpretations require human review and approval. Automated suggestions are starting points, not final answers.

NOT Complete Coverage

We do not cover all regulations, all obligations, or all jurisdictions.

Regulatory landscape is vast and evolving. Gaps in our coverage do not mean those requirements don't apply to you.

What This Tool IS:

  • A structured workflow for mapping regulatory requirements to implementation tasks
  • A documentation system for compliance decisions (audit trail)
  • A collaboration platform for compliance, legal, and engineering teams
  • An informational resource for understanding regulatory obligations