DSA40 DATA ACCESS DAYS

The first DSA40 Data Access Days brought together different stakeholders from all kinds of backgrounds to connect, exchange, and collaborate around data access.

25. and 26. September 2025 in Berlin.

Day 1: Looking back and ahead

On 25 September, the first days of the DSA40 Data Access Days organised by the DSA40 Data Access Collaboratory, over 100 participants from academia, civil society, authorities and online platforms gathered at the Weizenbaum Institute in Berlin to share experiences with accessing public data under Art. 40(12) and to look ahead to soon be able to submit requests for non-public platform data under Art. 40(4) DSA.

Keynote: Article 40 won’t save us (but it still might help)

Rebekah Tromble from George Washington University kicked the first day off by drawing a mixed picture of researcher access to platform data under the Digital Services Act (DSA) in her opening keynote.

“The community is coming together”

Tracing the evolution from limited predecessor frameworks, to the DSA’s landmark Article 40, Tromble also reflected on the recent backlash against data access advocates. Yet, she struck a hopeful note: “The community is coming together, across civil society and academia, we are talking, trusting, and supporting each other”. With regard to the soon possible access to non-public data, her advice was to build common use data sets in research infrastructure environments, agree on standard variables, and collaborate across institutions and jurisdictions, to submit applications and systematize lessons learned.

Panel: Looking back on 40.12

Panelists Daniela Alvarado Rincon (Democracy Reporting International), Anna Katzky-Reinshagen (Institute for Strategic Dialogue), Lion Wedel (Weizenbaum Institute) and Claire Pershan (Mozilla) highlighted that Art. 40(12) has fostered first insights into platforms’ access models, built a legal ground for scraping, and brought the public interest community together. Still, they voiced frustrations over restrictive API access, unannounced changes, slow responses and unjustified rejections, calling for standardised access flows and better communication channels.

Expert talks

Julian Jaursch (German DSC) presented the Data Access Portal and how national authorities will need to cooperate when reviewing applications. He also provided guidance on what kind of documentation researchers should include when applying, making special note of the fact that applications should carefully outline the lifecycle of data use.

Jeff Allen (Integrity Institute) shared insights on foundations of data engineering to inform researchers about platforms’ organisation of data. Explaining fact and dimension tables, he informed researchers how they could combine platform data across multiple tables.

Katrin Weller (GESIS) underscored the need for research infrastructure to study platform data. She pointed towards data management support, for example in the drafting of data management plans, the provision of secure processing environments and the consideration of secondary data usage.

Closing plenary: the big picture of data access

The closing plenary broadened the view. According to Anna Lührmann (member of the German parliament), data access is “the least the platforms can do” given their central role in public discourse. Regarding research on systemic risks, Judith Möller (Hans-Bredow-Institut) reminded that “we won’t have answers tomorrow and we will have different answers” than possibly expected, emphasising the time and funding required for reliable social media research.

“The least the platforms can do”

Silvia Mersiso (DG CNECT) and Johannes Heidelberger (German DSC) stressed coordination between national DSCs and the European Commission, especially on evidence thresholds and systematic pipelines for collecting evidence.

Day 2: Hands-on sessions

On day two, around 40 researchers reviewed the application requirements in the Delegated Act. Supported by AWO and the Integrity Institute, small groups came together to coordinate around and to start drafting 40(4) requests. Key advice included preparing robust data management plans, and requesting longer access periods upfront.