Beyond Disclosure: Rethinking Transparency and Digital Vulnerability under the Digital Services Act

Elif Beyza Akkanat-Öztürk

Keywords: Digital Services Act, transparency paradox, digital vulnerability, user empowerment, information asymmetry, EU platform regulation.

TL;DR: The paper argues that the DSA’s transparency rules risk reinforcing digital vulnerability through complex disclosures. It calls for user-centric, context-aware transparency to address power imbalances in platform governance.

Abstract: The Digital Services Act (DSA) marks a paradigm shift in platform governance, placing transparency at the heart of regulatory efforts. Yet despite its promise to rebalance power asymmetries between users and platforms, this paper argues that the DSA’s transparency obligations may create an unintended “transparency paradox,” where the sheer volume and technicality of disclosures risk reinforcing, rather than reducing, digital vulnerability. Drawing on legal theory and empirical insights, this paper critically assesses the DSA’s transparency regime considering users’ cognitive constraints, interface design patterns, and informational inequality. It argues that formal compliance with transparency norms does not necessarily yield meaningful understanding or user empowerment. Instead, it may obscure the structural power dynamics embedded in platform design and data governance. Building on interdisciplinary research, the paper proposes a shift from data-dump transparency toward contextual, user-tested, and layered communication strategies. By reframing transparency as a substantive, user-centric principle, this study offers normative and practical recommendations for European Union (EU) digital regulation to better address digitally enhanced power asymmetries and promote democratic information environments.

Submission Number: 2