Access to data by vetted researchers

Providers of very large online platforms (VLOP) and Very Large Online Search Engines (VLOSE) shall, upon a reasoned request from the digital services coordinator (DSC) of the country where they are established and within a reasonable period of time, provide vetted researchers who meet certain requirements with access to data. This access shall be granted for the exclusive purpose of carrying out investigations which contribute to the detection identification or appraisal of systemic risks in the European Union1 and which seek to assess the adequacy, efficiency and impact of measures adopted by VLOP and VLOSE providers to mitigate these risks.

Who assigns the status of vetted researcher

The status of vetted researcher is granted, following submission of a duly substantiated request from researchers, by the DSC of establishment of the VLOP or VLOSE provider whose data is to be accessed2. The request may also be submitted by researchers to the DSC of establishment of the research organisation to which they are affiliated. This DSC carries out an initial assessment to determine whether the researchers meet all the conditions set out in the DSA and subsequently sends the request, together with the supporting documents presented by the researchers, together with its initial assessment, to the DSC of establishment of the VLOP or VLOSE provider3.

Conditions for granting vetted researcher status

For the purposes of granting the status of vetted researcher, researchers must meet the conditions set out in the DSA, including the following conditions4:

  • They are affiliated to a research organisation;
  • They are independent from commercial interests;
  • Their application discloses the funding of the research;
  • They are capable of fulfilling the specific data security and confidentiality requirements corresponding to each request and to protect personal data, and they describe in their request the appropriate technical and organisational measures that they have put in place to this end;
  • Their application demonstrates that their access to the data and the time frames requested are necessary for, and proportionate to, the purposes of their research;
  • Their application demonstrates that the planned research activities will be carried out for the purposes of detecting, identifying and understanding systemic risks in the EU and assessing the adequacy, efficiency and impact of measures taken by the VLOP or VLOSE provider to mitigate those systemic risks, as well as that the expected results of the investigation contribute to these purposes;
  • They have committed themselves to making their research results publicly available free of charge, within a reasonable period after the completion of the research.

Requesting vetted researcher status

Vetted researcher status must be requested from ANACOM, as DSC in Portugal, via the email address

Supervision of vetted researcher status

The DSC that granted the status and issued the reasoned data access request with respect to the VLOP or VLOSE provider in question may conduct an investigation into a vetted researcher, on their own initiative or based on information received from third parties. Where the DSC concludes that the vetted researcher no longer complies with the conditions set out in the Digital Services Act (DSA)5, the DSC will adopt a decision terminating access and informing the VLOP or VLOSE provider.

1 Article 34 of the DSA.
2 Article 40(8) of the DSA.
3 Article 40(9) of the DSA.
4 Article 40(8) of the DSA.
5 Article 40(8) of the DSA.