M. Zimmer, P. Ducros, Pedro Cavalcante, Mustapha Jid, Rafiga Malikova, Bouthayna Mesraf, Luisa Perez
2026.5.25International Review of Law, Computers and Technology
Abstract
As political campaigns increasingly take place on online platforms, ensuring transparency in content moderation has become a democratic imperative. Article 24(5) of the Digital Services Act (DSA) requires platforms to submit all restriction decisions (‘Statements of Reasons’, Article 17 DSA) to the DSA Transparency Database (DSA-TDB), aiming to render moderation practices subject to scrutiny. However, whether this tool can meaningfully assess platform moderation in sensitive democratic contexts remains unclear. This article argues that the DSA-TDB introduces an unprecedented form of systemic transparency, yet its current design limits its capacity to support meaningful electoral oversight, thereby producing ‘opacified transparency’: a regime of disclosure that satisfies formal requirements without enabling meaningful verification in practice. Through a case study of TikTok’s moderation during the first round of the 2024 Romanian presidential election, drawing on 212 million SoRs, the article examines the database’s analytical potential and limits. The empirical analysis identifies intensified moderation around election day and apparent delays in removal orders issued by the Romanian electoral authority. Three structural features of the DSA-TDB – reliance on generic categories, weak territorial attribution, and lack of access to moderated content – significantly constrain national-level electoral auditing, leaving an architecture that risks generating visibility without verifiability.
Citation format
ZIMMER, M., et al. Opacified transparency? Assessing the DSA transparency database via tiktok's moderation during the 2024 romanian presidential election. International Review of Law, Computers and Technology, 2026: 1–21.