• The DSA is targeted at the service provider (Wikimedia Foundation), not the community content moderation
• The WMF will have to appoint a legal representative in the EU for which it will  need to choose a country
  
• The notice & action system means that how a user sends complaints to the WMF is now clear and the stages that follow.
  
• The WMF will have to do annual risk assessments for systemic risks and mitigation reports based on them
• The WMF will need to find an auditor to control the risk assessment and mitigation measures
• The WMF will need to publish its EU user estimate every three months
• The WMF will have to pay a VLOP fee to the European Commission
• The WMF is expected to contribute to the EU's moderation decision database
• The WMF will need to demonstrate how it protects minors on Wikipedia

=== Digital Services Act ===

WE ARE VLOP. Officially. [1] For those less acquainted with EU terminology: Wikipedia has been designated as a Very Large Online Platform by the European Commission, which means that the WMF will have to comply with the strictest obligations under the Digital Services Act, including regular risk assessments for systemic risks (including things like public health, kids’ safety and freedom of expression), publishing mitigation measures based on them, and then undergoing an external audit. Wikipedia is the only not-for-profit service that has been designated as a VLOP; the other 18 are for-profit. 

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This is a chance for Wikimedia to demonstrate that compliance with such rules can be done in a manner that respects user rights and keeps communities - not the platform operator - in the driving seat. The Wikimedia Foundation (WMF) is working on compliance and dedicating significant resources to this. The challenges are serious too. If regulators cannot be convinced that Wikipedia is properly addressing “systemic risks”, like election manipulation, then WMF and the community will be challenged to find additional responses to that.  There’s also substantial “bureaucracy”: VLOP designation means that the WMF needs to appoint a legal representative in the EU. It needs to adjust internal processes so they are in line with the new “notice & action” framework, it has to set up a process on how to conduct risk assessments and mitigation reports (annually, and before making significant changes to things), and to find an appropriate auditor who will grill it on all of these things. 

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VLOPs are also expected to contribute to the European Commission’s moderation decision database (though whether and how such a database can comply with EU privacy laws, remains to be seen). Plus, there remains the not inconsequential task of ensuring all of the other Wikimedia projects - such as Commons - comply with the DSA’s more general rules.  That’s a lot of work - and so is convincing the regulators to not forget our model when they’re writing the guidance and implementing rules - and it is handled by very lean teams (as openly and collaboratively as they can manage - witness the TOU update).