Legislation · European Union · EU Directive & Regulation (Regulation (EU) 2022/2065)

EU Digital Services Act (DSA)

The DSA establishes the liability and transparency framework for intermediary services in the EU — marketplaces in particular. Its practical significance for Turkish sellers lies in trader verification (KYBC), the obligation to give reasons for account restrictions, and appeal mechanisms.

In forceIn force · 17.02.2024 (full application)Source · ABl. L 277, 27.10.2022Threshold · Intermediary services; additional obligations increase with scale
In summary

The Regulation introduces a notice-and-action mechanism against illegal content and products, a statement of reasons and internal complaint system for decisions, advertising transparency, and — for marketplaces — traceability of traders (KYBC) obligations. The layer of obligations increases with the scale of the service (VLOP/VLOSE).

Overview

The Digital Services Act (DSA) updates the liability regime for intermediary service providers in the EU — access, hosting, platforms and marketplaces. The “safe harbour” inherited from the e-Commerce Directive is preserved, but comprehensive due-diligence and transparency obligations are built on top of it.

What it means for marketplace sellers

Turkish companies selling on EU marketplaces feel the DSA most acutely at three points: identity, address and registry documents under seller verification (know-your-business-customer); compliance information in product listings; and the platform’s obligation to state reasons and provide an appeal route when it restricts an account. This last rule is the seller’s strongest footing in suspension disputes.

Those running their own platform

Turkish platforms offering services aimed at EU users fall within scope even if they are not established there, and must appoint a legal representative in the EU. Terms of use, moderation processes and transparency reports must be adapted to the language of the DSA.

Key point for the Turkish side

For suspended accounts, the process is no longer left entirely to the platform’s mercy: the steps of a statement of reasons, an internal complaint and certified dispute resolution can be demanded as a matter of law. The state of your evidence and correspondence determines the outcome.

Roadmap

For sellers: keeping the verification file ready, listing compliance information, and an appeal strategy in the event of a restriction. For platforms: scope and representative analysis, revision of the terms set, and notice-and-action and reporting arrangements.

Penalties

For breaches, administrative fines of up to 6% of global annual turnover are envisaged; for very large platforms (VLOP/VLOSE), supervision rests directly with the European Commission. For sellers, the real practical sanction is the platforms’ DSA-driven verification and restriction practices.

Related content

For its Turkish counterpart, see the Law No. 6563 record. Marketplace sellers’ rights and suspension appeals are covered in our International E-Commerce focus; the market-entry plan is in our EU e-commerce guide.

What it means in practice

The DSA has entered its enforcement era: the Commission’s decisions against X and Temu show the obligations are not theoretical. For sellers reaching the EU from Türkiye, the most concrete impact is marketplace trader-traceability checks — missing or unverifiable seller information leads to listings being taken down by the platform itself.

This record is provided for general information and monitoring only; it does not constitute legal advice or create an attorney–client relationship. The official text in force is authoritative. Contact our team for a scope and compliance assessment specific to your company.
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Legislation · European Union

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