Towards More Granular Reasoning: Mapping the DSA Transparency Database Taxonomy to Platform Terms and Conditions Using Large Language Models

Alyson Ranucci, Eline Leijten, David Graus

Article 24(5) of the Digital Services Act (DSA) requires providers of online platforms to submit every content moderation decision they make, with a corresponding Statement of Reasons (SoR), to the DSA Transparency Database (DSA-TDB). Such decisions are classified against seventeen high-level attribute categories that categorize the primary reason for the moderation decision. Because over 99.8% of statements cite a violation of the provider's own terms and conditions rather than a legal provision, the database is overwhelmingly a record of contractual enforcement using catch-all reporting; however, whether its categories actually describe those contractual rules well has not been examined. In this paper, we map the terms and conditions (T&C) of 31 designated online services against the DSA-TDB's high-level category taxonomy using a few-shot GPT-4.1 classifier over 447 policy documents. The analysis concerns how T&C rules are represented in the taxonomy, not how they are enforced. Two findings emerge. First, high-level category applicability varies sharply by service type: unsafe products account for 17.5% of e-commerce assignments and 0.2% of adult-platform assignments, and…