This second report on the hub activity in monitoring the implementation of the CoC and DSA in the region presents the main findings with a particular focus on platform disengagement, the role of Digital Services Coordinators (DSCs), and the persistent challenges related to data access already identified in previous reporting. The analysis draws on cross-cutting findings from the two most recent CEDMO summary notes (October 2025 and April 2026), allowing for a comparative perspective on evolving trends. This report also builds on a strong engagement from an important number of experts and organisations operating in the region, whose contributions provide a detailed and grounded assessment of current practices.

The analysis focuses primarily on the role of Very Large Online Platforms (VLOPs), designated under the Digital Services Act (DSA), and their adherence to the voluntary commitments outlined in the Code. The DSA establishes a new binding regulatory framework for online platforms in the EU, with the Code of Conduct on disinformation providing a primary framework for VLOPs to demonstrate their efforts to address disinformation. Effective implementation of both is therefore critical for the resilience of Europe’s information space.

The report is structured to examine the key operational and governance challenges identified through stakeholder engagement and platform transparency biannual reporting:

• Data Access
• Platform Engagement and fact-checking
• Media and Information Literacy
• National level implementation challenges
• Generative AI as an emerging risk multiplier.

Authors: Amine BIDAR, Jana SOUKOUPOVA, Jana KAZAZ