In short. A user-content function can qualify as DSA hosting when it stores user-provided information on request, while online-platform status adds public dissemination and an ancillary-feature test.
Definition: A website's user-content function can be a hosting service under the Digital Services Act (DSA) when it qualifies as an information society service and stores information provided by a user at that user's request. An online platform is a subcategory of hosting service that also disseminates that information to the public, subject to an ancillary-feature exception in Article 3(i).
Key facts
- The DSA's Article 3(g)(iii) defines hosting by storage of recipient-provided information at the recipient's request.
- An information society service is normally provided for remuneration, at a distance, electronically and on individual request, under Article 1(1)(b) of Directive (EU) 2015/1535.
- As of 17 October 2026, the European Commission's DSA questions and answers explains that small and micro-enterprises have exemptions from some rules.
What makes a website function an intermediary service?
An information society service has the characteristics set out above. Directive (EU) 2015/1535, Article 1(1)(b), further explains that provision at a distance means the parties are not simultaneously present. An individual request involves transmission of data on request.
The DSA's Article 3(g) groups intermediary services into mere conduit, caching and hosting. Mere conduit covers transmission of user-provided information or network access. Caching involves automatic, intermediate, temporary storage to make onward transmission more efficient. Hosting consists of storing information provided by, and at the request of, a recipient. Article 3(b) defines that recipient as a person or legal entity using the intermediary service.
Recital 29 requires classification by technical functionality on a case-by-case basis. Recital 15 explains that, when a provider offers different services, the relevant provisions apply to the services within their scope. Article 2(1) covers intermediary services offered to recipients established or located in the EU, irrespective of the provider's establishment; Article 3(d) requires a substantial connection to the EU.
When does hosting become an online platform?
Under DSA Article 3(i) and (k), an online platform stores and disseminates information to the public at a recipient's request. Public dissemination means making information available to a potentially unlimited number of third parties.
The exception concerns an activity that is a minor and purely ancillary feature of another service, or a minor functionality of the principal service. For objective and technical reasons, it must be unusable without that other service, and its integration must not circumvent the DSA.
Recital 13 gives an online newspaper's comments section as a possible example where comments are ancillary to publishing news under the publisher's editorial responsibility. It contrasts this with social-network comments where storage is more than a minor feature. The exception concerns online-platform classification; the storage function still falls to be assessed against the hosting definition.
Does being small remove hosting duties?
DSA Article 19 excludes qualifying micro and small enterprises from the additional online-platform obligations in Chapter III, Section 3, except Article 24(3). It retains those obligations for designated very large online platforms. The hosting definition in Article 3(g)(iii) contains no business-size threshold.
Hosting duties appear separately in Chapter III, Section 2. Article 16(1) requires a mechanism for individuals or entities to report specific information they consider illegal. That mechanism must be easy to access, user-friendly and allow electronic submission.
Related terms
- What must an illegal-content notice mechanism contain under the DSA?
- Which DSA platform duties have a microenterprise exemption?
- Does DSA Article 8 require a host to monitor every user submission?
FAQ
Does a login make my user content private for this definition?
DSA recital 14 explains that registration can still involve public dissemination when admission is automatic, without a human decision selecting who receives access.
Does my newspaper comments section automatically make it an online platform?
DSA recital 13 identifies newspaper comments as a possible ancillary feature. Article 3(i)'s conditions determine whether the exception applies.
Does my web-hosting supplier's role settle my website's classification?
DSA recital 13 treats underlying storage infrastructure separately: a web host serving as infrastructure is not itself considered to disseminate its customer's user information to the public. Recital 29 bases service classification on technical functionalities.
Sources
- European Parliament and Council, "Digital Services Act, Regulation (EU) 2022/2065", 19 October 2022
- European Parliament and Council, "Directive (EU) 2015/1535", 9 September 2015
- European Commission, "Digital Services Act: Questions and Answers", updated 19 December 2025
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