# Compliance Function Establishment and Role — legal context bundle > Curated from overview.legal on 2026-08-22. Canonical page: https://overview.legal/topics/compliance-function-establishment-role > Sources are cited per item. Verify against the official texts before relying on them. The DSA content specifically addresses compliance functions as organizational entities with defined roles, responsibilities, and governance structures. This topic is needed to comprehensively cover the establishment, structure, and operational framework of compliance functions under DSA requirements. ## Overview ## Legal Framework Article 41 of the DSA imposes a mandatory compliance function on providers of very large online platforms (VLOPs) and very large online search engines (VLOSEs). Recital 99 clarifies the rationale: given the systemic risks these services present to society, a dedicated compliance function must operate independently from operational units. The head of this function must report directly to the provider's management body, including when raising concerns about non-compliance with the Regulation. Compliance officers within the function must possess the necessary qualifications, knowledge, and experience to discharge their duties effectively. The compliance function's core mandate is to monitor and advise on the provider's adherence to DSA obligations — spanning risk assessments, mitigation measures, content moderation systems, advertising transparency, and data access requirements. The structural independence requirement means the function cannot be subordinated to commercial or operational teams whose priorities may conflict with regulatory compliance. ## Key Developments Enforcement activity under the DSA remains at an early stage, but the European Commission's proceedings against designated VLOPs signal how Article 41 will be scrutinized in practice. The Commission's opening of formal investigations against platforms including X, TikTok, and Meta has included examination of whether internal governance structures — including compliance functions — are adequately resourced and positioned to meet DSA standards. The February 2026 matter involving AppLogic Networks in Egypt illustrates the human rights and press freedom dimensions that compliance functions must be equipped to identify and escalate. Where platform infrastructure facilitates abuses that implicate DSA risk categories, the compliance function's independence and direct reporting line become critical to ensuring concerns reach management without operational filtering. ## Practical Guidance - **Establish structural separation**: The compliance function must sit outside operational reporting lines. Personnel should not report to product, engineering, or commercial leadership. A direct reporting line from the head of compliance to the management body satisfies Article 41's independence requirement. - **Define the mandate in writing**: Charter the compliance function's scope to cover all DSA obligations — Articles 34–35 risk assessments and mitigation, Article 16 notice-and-action, Article 24 advertising repositories, and Article 40 data access. Ambiguity in scope invites enforcement gaps. - **Resource the function commensurately with systemic risk exposure**: Recital 99's qualifications requirement means staffing must reflect the scale and complexity of the platform. Under-resourced compliance teams will not satisfy the standard. - **Build an escalation mechanism for non-compliance concerns**: The head of compliance must be able to raise concerns directly with management. Document the escalation pathway and ensure it cannot be blocked by intermediate operational layers. - **Integrate compliance function input into risk assessment cycles**: Article 34 risk assessments should involve the compliance function as a substantive contributor, not merely a reviewer, to ensure identified risks translate into actionable mitigation under Article 35. ## Legislation (full text of key provisions) ### Compliance function *Source: DSA, dsa-art-41-en, 2022-10-19 — https://overview.legal/posts/94732* ### Recital 99 — independent compliance function for very large online platforms *Source: DSA, dsa-rec-99-en, 2022-10-19 — https://overview.legal/posts/95595* Given the complexity of the functioning of the systems deployed and the systemic risks they present to society, providers of very large online platforms and of very large online search engines should establish a compliance function, which should be independent from the operational functions of those providers. The head of the compliance function should report directly to the management of those providers, including for concerns of non-compliance with this Regulation. The compliance officers that are part of the compliance function should have the necessary qualifications, knowledge, experience and ability to operationalise measures and monitor the compliance with this Regulation within the organisation of the providers of very large online platform or of very large online search engine. Providers of very large online platforms and of very large online search engines should ensure that the compliance function is involved, properly and in a timely manner, in all issues which relate to this Regulation including in the risk assessment and mitigation strategy and specific measures, as well as assessing compliance, where applicable, with commitments made by those providers under the codes of conduct and crisis protocols they subscribe to. ## Recent developments ### Data Protection Officer or Chief Privacy Officer?The rise of the Data Protection Officer *Source: White Label Consultancy, 2022-01-04 — https://overview.legal/posts/6311 — original: https://whitelabelconsultancy.com/2022/01/chief-privacy-officer-or-data-protection-officer/#entry-16* > Do we need an Chief Privacy Officer, a Data Protection Officer, or do we need both?In the following article, I will examine the benefits of both roles, but I will also look at some of the challenges related to each of the roles and why these have impelled both Data Protection Officers and organisations to question what the ideal setup is for them. ## Related topics - **VLOP/VLSE Framework** — https://overview.legal/topics/vlop-vlse-regulatory-framework-overview The content title specifically focuses on 'Very large online platforms and very large online search engines' as a distinct regulatory category under the DSA. A - **Compliance Independence** — https://overview.legal/topics/compliance-function-independence-impartiality DSA compliance functions require independence and impartiality to effectively monitor and enforce compliance. This topic is needed to address the specific requi - **Profiling** — https://overview.legal/topics/profiling Automated processing to evaluate personal aspects - **Supervisory Authorities** — https://overview.legal/topics/supervisory-authorities National data protection authorities and their powers - **Public Sector** — https://overview.legal/topics/public-sector Processing by public authorities - **Insurance** — https://overview.legal/topics/insurance Processing by insurance companies --- Generated by overview.legal · https://overview.legal/topics/compliance-function-establishment-role · 2026-08-22