Accessibility –Application of EAA
DATE OF UPDATE: 28 June 2025
IMPLEMENTATION/DEADLINE DATE:
28 June 2025
CURRENT STATUS
The European Accessibility Act (Directive (EU) 2019/882) (EAA) aims to harmonise accessibility requirements across the EU to ensure that certain products and services are accessible to all, particularly those with disabilities. It has been implemented into Irish law by SI No. 636/2023 the European Union (Accessibility Requirements of Products and Services) Regulations 2023 (Irish Regulations).
WHY IS THIS APPLICABLE TO CLIENTS?
Organisations should consider whether the products and services they provide fall within the scope of the EAA and what measures, if any, need to be taken to ensure their compliance with the legislation. In doing so, organisations should be conscious of the application date and transitional measures.
European Media Freedom Act – Article 18 -Moderation of Content by VLOPs
DATE OF UPDATE: 23 June 2025
IMPLEMENTATION/DEADLINE DATE:
The feedback period runs until 23 July 2025.
CURRENT STATUS
The European Commission is seeking feedback on guidelines on content moderation by very large online platforms designated under Regulation (EU) 2022/2065 (Digital Services Act or DSA). The guidelines will assist these platforms in implementing specific safeguards outlined in the European Media Freedom Act.
WHY IS THIS APPLICABLE TO CLIENTS?
The consultation paper builds on preliminary exchanges held with representatives of providers of very large online platforms, media service providers, civil society organizations and fact-checking organisations.
DSA – Enforcement - AliExpress
DATE OF UPDATE: 18 June 2025
CURRENT STATUS
The Commission accepted and made binding a series of commitments offered by AliExpress to settle a number of concerns, such as the platform's transparency on advertising and recommender systems.
The Commission also made preliminary findings that AliExpress breached its obligation to assess and mitigate risks related to the dissemination of illegal products under the DSA. AliExpress was designated as a Very Large Online Platform (VLOP) on 25 April 2023.
WHY IS THIS APPLICABLE TO CLIENTS?
The enforcement activities of the Commission under the DSA will be of interest to other VLOPs and online intermediaries.
Regulation (EU) 2021/784 on addressing the dissemination of terrorist content online (TCO Regulation)
DATE OF UPDATE: 18 June 2025
CURRENT STATUS
The Commission decided to refer Bulgaria, Ireland and Portugal to the Court of Justice of the European Union for failing to comply with certain obligations from the TCO Regulation, which became applicable on 7 June 2022.
WHY IS THIS APPLICABLE TO CLIENTS?
The TCO Regulation requires that terrorist content in the EU is taken down by online platforms within one hour upon receipt of a removal order issued by Member States' authorities.
Coimisiún na Meán (CnaM) – Enforcement - X
DATE OF UPDATE: 17 June 2025
IMPLEMENTATION/DEADLINE DATE:
X is obliged to respond by 22 July 2025.
CURRENT STATUS
CnaM issued a statutory Information Notice to X Internet Unlimited Company, the provider of the platform X. It is seeking information in relation to measures in place to protect children using the service.
Under Section 139O of the Broadcasting Act, a statutory Information Notice compels the recipient to provide information relating to its compliance with the Online Safety Code.
WHY IS THIS APPLICABLE TO CLIENTS?
The enforcement activities of CnaM as regards the Online Safety Code will be of interest to other video-sharing platforms that have their EU headquarters in Ireland as well as users of their video-sharing services.
Report on the Conduct of 2024 Elections
DATE OF UPDATE: 6 June 2025
CURRENT STATUS
The European Commission has published a Report on the 2024 elections to the European Parliament.
WHY IS THIS APPLICABLE TO CLIENTS?
The Report makes reference to the application of Code of Disinformation and the DSA in the context of elections and will be of interest to online intermediaries.
DSA – Enforcement
DATE OF UPDATE: 27 May 2025
CURRENT STATUS
The European Commission announced preliminarily findings that Pornhub, Stripchat, XNXX, and XVideos have breached the DSA. The findings relate to a lack of measures to ensure the safeguarding of minors.
In parallel, the Commission announced the termination of the designation of Stripchat as a Very Large Online Platform, due to lower numbers of recipients.
WHY IS THIS APPLICABLE TO CLIENTS?
Protecting young users online is one of the key enforcement priorities under the DSA as demonstrated by the Commission’s investigation and the other actions set out below.
NEXT STEPS
The Commission will now conduct a further in-depth investigation to gather evidence.
Digital Services Coordinator (DSC) Enforcement
DATE OF UPDATE: 27 May 2025
LINKS
CURRENT STATUS
The European Board for Digital Services launched a coordinated action to reinforce the protection of minors as regards pornographic platforms. DSCs, where necessary in cooperation with other national competent authorities, plan to identify pornographic platforms and evaluate their age verification measures with a view to taking investigative and enforcement action, where necessary.
WHY IS THIS APPLICABLE TO CLIENTS?
This action reflects the growth of enforcement activity focused on the protection of children online.
Clients will also be aware of the imperative in the GDPR to provide specific protection for children with regard to their personal data, as illustrated, for example in the DPC’s decision in 2023 on the processing by TikTok Technology Limited of personal data relating to child users of the TikTok platform.
Broadcasting Act 2009 – Reddit
DATE OF UPDATE: 23 May 2025
CURRENT STATUS
Coimisiún na Meán, pursuant to Section 139I of the Broadcasting Act 2009 and after consultation with Reddit, Inc., and Reddit Netherlands B.V. revoked the designation of Reddit as a named video-sharing platform service, as it no longer under the jurisdiction of the State.
WHY IS THIS APPLICABLE TO CLIENTS?
Reddit’s service to users in the EU is now provided by a Dutch entity. This means that CnaM’s online safety codes no longer apply to the service and illustrates the application of the EU country-of-origin principle.
EU Business Wallet
DATE OF UPDATE: 15 May 2025
IMPLEMENTATION/DEADLINE DATE:
Feedback period ended on 12 June 2025
CURRENT STATUS
The Commission launched a Call for Evidence in relation to the EU Business Wallet.
The initiative aims to establish a universally accepted digital identification and authentication system for economic operators and public administrations.
WHY IS THIS APPLICABLE TO CLIENTS?
The Wallet is designed to improve business efficiency and reduce the number of resources allocated to administrative procedure.
Consumer Online Platform Providers Levy Order 2025
DATE OF UPDATE: 14 May 2025
IMPLEMENTATION/DEADLINE DATE:
The Order came into operation on 1 June 2025.
CURRENT STATUS
This Order imposes a levy on consumer online platform providers sufficient to meet the Competition and Consumer Protection Commission’s expenses and its working capital requirements incurred in the levy period relating to the performance of its functions as the competent authority in respect of Articles 30, 31 and 32 of DSA as designated by section 44 of the Digital Services Act 2024.
WHY IS THIS APPLICABLE TO CLIENTS?
The Order will be of relevance to consumer online platform providers.
DSA – Protection of Minors Online
DATE OF UPDATE: 12 May 2025
IMPLEMENTATION/DEADLINE DATE:
The draft guidelines were open for final public feedback until 10 June 2025.
CURRENT STATUS
The Commission launched a public consultation on its draft guidelines on the protection of minors online, which aim to assist online platforms in ensuring a high level of privacy, safety, and security for children online.
WHY IS THIS APPLICABLE TO CLIENTS?
The guidelines outline a non-exhaustive list of measures that all platforms, except for micro and small enterprises, can implement to protect minors, using a default approach that is guided by privacy by design.
NEXT STEPS
The Commission is developing a white label age-verification app, intended to bridge the gap until the EU Digital Wallet becomes available by the end of 2026.
DSA- Trusted Flagger
CURRENT STATUS
The Central Bank of Ireland was awarded Trusted Flagger status under the DSA.
Trusted Flaggers are empowered to identify, detect and notify illegal content within their area of expertise to online platforms.
WHY IS THIS APPLICABLE TO THE CLIENT?
Providers of online platforms will take note of the appointment of Trusted Flaggers and ensure these entities are clearly identified within their moderation processes.
DSA - Thirteenth Meeting of the European Board for Digital Services (EBDS)
DATE OF UPDATE: 29 April 2025
CURRENT STATUS
During the meeting, the Commission and the Digital Services Coordinators shared updates on recent developments and enforcement actions. The EBDS discussed the upcoming Board report concerning prominent systemic risks under Article 35(2) DSA, its consultation regarding the revised draft delegated act on data access, updates on the work on the protection of minors, the revised draft incident response framework, and international issues and organizational aspects of the Board meetings.
WHY IS THIS APPLICABLE TO THE CLIENT?
The work plans of the EBDS will be of interest to entities regulated under the DSA and for those organisations and individuals that avail of their services.
WHAT NEXT?
The next Board meeting was scheduled to take place on 27 June 2025, in Brussels.
Strategy and Enforcement - Coimisiún na Meán
DATE OF UPDATE: 24 April 2025
CURRENT STATUS
Coimisiún na Meán published its first 3-year strategy, which sets out the organisation’s vision for a vibrant and healthy media landscape in Ireland. The Strategy Statement 2025-2027 is accompanied by a 2025 Work Programme, which lists priority projects across Coimisiún na Meán’s remit of online safety, media sector development, and regulation.
WHY IS THIS APPLICABLE TO THE CLIENT?
Among the priority projects outlined in the 2025 Work Programme are the development of a pilot programme for children at imminent risk of harm from online content, the development of an Election Strategy across all media sources, and the creation of educational materials relating to online hate.
National Counter Disinformation Strategy
DATE OF UPDATE: 17 April 2025
CURRENT STATUS
The Government published its National Disinformation Strategy. The Strategy fulfils a recommendation of the Future of Media Commission and explores the challenge of disinformation in Ireland. It seeks to identify how the challenge of countering disinformation may be met, although it does not make recommendations. Instead, it sets out nine overarching commitments and 36 actions.
WHY IS THIS APPLICABLE TO THE CLIENT?
Measures to counter disinformation online will be relevant to online intermediaries and media organisations established in Ireland.
Online Content – Fact-Checking
DATE OF UPDATE: 15 April 2025
IMPLEMENTATION/DEADLINE DATE:
02 September 2025
CURRENT STATUS
The European Commission has launched a call for proposals to support the growth of a European Network of Fact-Checkers, in line with President von der Leyen’s 2024–2029 political guidelines. It aims to strengthen the capacity of the European fact-checking community and make fact-checking available in all languages, building on and further expanding activities initially carried out by European Digital Media Observatory (EDMO) and other European fact-checking initiatives like the European Fact-Checking Standards Network (EFCSN). Activities may also cover candidate and accession countries associated with the Programme, in view of the specific vulnerabilities to disinformation and Russian interference in this region.
WHY IS THIS APPLICABLE TO THE CLIENT?
This call, combined with a further two calls for proposals in relation to malicious information manipulation campaigns and to fact-checking, both launched on 30 April 2025, demonstrate the concern within the EU regarding the spread of disinformation.
Accessibility – Rules for Microenterprises
CURRENT STATUS
To prepare for the entry into force of the European Accessibility Act (Directive (EU) 2019/882) on 28 June 2025, the Competition and Consumer Protection Commission (CCPC) has worked with the National Disability Authority to develop guidelines for microenterprises on their accessibility obligations. The CCPC invited feedback on these guidelines through a public consultation.
WHY IS THIS APPLICABLE TO THE CLIENT?
While the guidelines will apply to microenterprises, they may nonetheless offer insight into the enforcement of the Directive in Ireland.
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