The Global Network Initiative (GNI) is grateful for the opportunity to provide input on the draft delegated regulation on independent audits of very large online platforms and very large online search engines (“draft delegated regulation”), as required under Article 37 of the Digital Services Act (DSA). GNI has engaged in earlier stages of consultations on the DSA and consistently expressed support for its focus on incentivizing the development of internal and external systems for identifying and mitigating risks, in line with the United Nations Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines on Multinational Enterprises (OECD Guidelines).

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The points raised in our submission stem from lessons GNI has learned over four cycles of multistakeholder “assessments” of the internal systems and processes used by information and communication technology (ICT) companies to identify and address risks to freedom of expression and privacy, as well as events that GNI has helped facilitate with a broader audience of experts through the Action Coalition on Meaningful Transparency, which GNI helped establish and manages. We remain committed to ensuring that the DSA achieves its objectives and sets a positive global example of how to address digital risks, while upholding and expanding digital rights.

We look forward to engaging in further discussion with the Commission and other stakeholders on these topics.