Click, Branch, Audit: A Decision-Tree Toolkit for Assessing Fundamental Rights Impacts under the Digital Services Act of Very Large Platforms & Search Engines

arXiv:2609.26353v1 Announce Type: new Abstract: The EU Digital Services Act (DSA) requires Very Large Online Platforms and Search Engines (VLOPs/VLOSEs) to assess and mitigate systemic risks, including actual or foreseeable negative effects on fundamental rights, and subjects these assessments to independent audit. Yet how such rights-relevant risks should be identified, assessed, evidenced, and documented remains methodologically under-specified. We address this gap by introducing a decision-tree-based toolkit that operationalizes Article 34(1)(b) DSA and related audit requirements into a structured assessment process. The toolkit decomposes platforms as systems-of-systems and guides assessors through DSA applicability, context definition, subsystem and stakeholder identification, risk identification, risk assessment, reporting, and visualization. A central design contribution is its treatment of vulnerability as situational and relational: rather than assigning vulnerability to fixed groups, the toolkit asks how particular platform subsystems and dependencies may place stakeholders in vulnerable positions. It further makes fundamental rights-relevant judgments traceable by recording the affected right, interference and justification analysis within the structure of a proportionality test, while also covering a perception and impact dimension including severity, scope, duration, reversibility, as well as practical consequences. We developed the toolkit iteratively through a design-science process combining literature-derived design requirements, three interdisciplinary exp

The toolkit aims to support assessments of fundamental rights impacts under the DSA.

The toolkit aims to enhance transparency and systematic assessment of fundamental rights risks in large digital platforms, which could improve oversight and reduce harm. However, it is a methodological tool and does not directly guarantee improved outcomes. Its impact depends on adoption and enforcement effectiveness.

This is a methodological governance tool, not evidence of actual societal impact from AI systems. It could modestly support better platform accountability if adopted, but is early-stage and validated only through small workshops, so implications remain speculative and mild.

This toolkit aims to help Very Large Online Platforms and Search Engines comply with the EU Digital Services Act by providing a structured method for assessing fundamental rights impacts. Its purpose is to streamline and increase the transparency and auditability of these assessments, which is a mildly positive development for human rights protection.

SOURCE     arXiv cs.CY (Computers and Society) (tier 1)
   ↓
DOCUMENT   9aa55f81-77cc-4f64-b72a-355e1356735b
           https://arxiv.org/abs/2609.26353
   ↓
EVIDENCE   1 extracted excerpt
   ↓
MODEL RUN  4 runs, methodology 1.0.1
   ↓
SCORE      -15  (Mixed or uncertain)
   ↓
CONFIDENCE 72%