Source: Freepik
Online research begins with data. Since October 29, 2025, new opportunities have opened up for researchers in the EU with the entry into force of the Digital Services Act (DSA) and the launch of the European Data Access Portal: For the first time, very large online platforms and search engines (VLOPs and VLOSEs) can be systematically investigated.
For projects in the field of research data management (RDM), this means that structured and legally compliant data can be directly incorporated into scientific work, whether for analyses, studies, or methodological developments. This access to data offers unique potential for researching how digital platforms work and better understanding the risks for users.
Why Is Access to Data Important for Research?
Digital platforms shape information flows, opinion formation, and economic processes. At the same time, they can pose systemic risks, for example with regard to the protection of children and young people, the dissemination of illegal content, or online fraud models.
The DSA responds to these challenges by allowing independent researchers access to platform data under certain conditions. The aim is to create more transparency and enable sound scientific analysis, which in turn can contribute to the further development of regulatory measures.
What Data Is Accessible?
The DSA distinguishes between two forms of data access:
- Publicly accessible data pursuant to Article 40, paragraph 12 DSA: Very large online platforms and search engines must allow researchers access to publicly available information. This includes profiles, content, follower numbers, and interaction data such as likes or clicks. No formal authorization is required for this access. The platforms usually provide their own application or access systems for this purpose.
- Non-publicly available data pursuant to Article 40, paragraph 4 DSA: For more in-depth scientific questions, authorized researchers can apply for access to internal data that is not publicly available. This data access is subject to strict conditions and a formalized review process.
Access to non-public data in particular opens up new opportunities to investigate systemic risks on a data-based basis, for example in connection with recommendation systems or risk mitigation measures.
How Does the Application Process Work?
Applications for access to non-public data are submitted via the European DSA Data Access Portal. Researchers must demonstrate, among other things:
- their institutional affiliation and the scientific nature of the research institution
- their independence from commercial interests
- the financing of the research project
- the specific research project and its relevance to systemic risks
- what data is needed, to what extent, and why this is necessary and proportionate
- what measures are planned to ensure data protection, data security, and confidentiality.
The Digital Services Coordinators of the member states are responsible for evaluating the applications. In Germany, this task is assigned to the Federal Network Agency. Data protection issues are examined in close coordination with the competent data protection authorities.
Role of the Digital Services Coordinator
The German Digital Services Coordinator (DSC) acts as the central coordinating body for the enforcement of the Digital Services Act. It monitors intermediary services, handles user complaints, certifies trusted flaggers, and reviews applications from researchers for data access. In this way, the DSC helps to ensure that access to sensitive platform data is made possible while at the same time complying with the law and data protection regulations.
What Does This Mean for Researchers?
The launch of the data access portal marks the beginning of a new era for platform research in Europe. Researchers will now have the opportunity to base their analyses on a broader and more robust data foundation. However, this requires well-prepared, transparent, and carefully substantiated requests.
The “Guide to Data Access for Researchers” published by the German DSC provides valuable guidance in this regard. It describes key requirements, necessary evidence, and typical review criteria.
Conclusion
Data access under the Digital Services Act opens up new perspectives for independent research on digital platforms and their social impact. At the same time, it is subject to clear legal, organizational, and data protection requirements.
Online access is beginning. This creates new opportunities for scientific analysis in the digital space.
If you have any questions about data access under the DSA, please contact the team at the German DSC directly. If you have any questions about topics related to the RDM, we are always happy to help. The RDM team looks forward to hearing from you and will be happy to assist you!
Responsible for the content of this article is Hania Eid.
The following sources served as the basis for this article:
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