Operational Readiness for DSA Alignment: An Expert Definition. Practical Checklist for EU Candidate Countries

The High‑Level Expert Group for Resilience Building in Eastern Europe (HLEG), coordinated by IMS (International Media Support), has published the first collective expert definition of what minimum operational readiness for Digital Services Act (DSA) alignment should mean in practice. The publication offers a practical framework for EU candidate countries navigating the pre-accession period in the digital domain.

In March 2026, the European Commission (DG Connect) clarified that candidate countries are not expected to fully transpose the DSA prior to accession, placing emphasis instead on operational readiness as a combination of institutional planning, capacity building and awareness-raising. At the same time, the practical meaning of operational readiness has remained open for interpretation, with candidate countries developing their own approaches in the absence of a shared framework.

It is at this juncture that HLEG puts forward its collective expert view on the minimum elements that should be in place to ensure operational preparedness in practice. This checklist is HLEG’s expert contribution to that conversation.

Candidate country context and a partnership-oriented approach

According to Kristina Rud, Coordinator of HLEG, EU candidate countries operate in significantly different political, institutional and security contexts – navigating war, elections, complex democratic transitions, diverse regulatory landscapes and challenging information environments. HLEG recognises that in such contexts, building effective platform governance requires more than legislative transposition – it requires genuine institutional capacity, robust safeguards for fundamental rights and meaningful multi-stakeholder participation.

HLEG proceeds from the understanding that European integration in the digital sphere is not a formal “exam” or a compliance test, but a process ofbuilding genuine partnershipbetween the EU and candidate countries. At the centre of this partnership should be citizens’ digital rights, platform accountability, the rule of law and the resilience of democratic institutions.

What the document covers

The document outlines 12 core elements of minimum operational readiness, structured around:

– institutional design, including the designation and independence of a future Digital Services Coordinator (DSC).
– legislative frameworks and pre‑accession legal instruments.
– practical preparedness of the state, the business community and the regulatory environment.
– public awareness‑raising and structured civil society participation.
– the enforcement ecosystem, including out‑of‑court dispute settlement
mechanisms and trusted flaggers.
– cooperation with EU institutions in advance of accession.

The checklist is not a regulatory standard and does not establish binding obligations. It is offered as a practical starting point to support shared understanding and informed discussion among candidate countries, EU institutions, civil society organisations and digital service providers. The document is intended for use by governments assessing their own readiness, by civil society organisations advocating for minimum preparedness standards, and by all actors engaged in shaping the digital governance landscape in countries moving towards closer alignment with EU frameworks.

HLEG contributing authors:

The High‑Level Expert Group for Resilience Building in Eastern Europe (HLEG) brings together independent experts with hands‑on experience in EU candidate countries across the fields of digital rights, media policy, freedom of expression, regulatory design and democratic governance.

– Kristina Rud, International Media Support.
– Pavlo Burdiak, Centre for Democracy and Rule of Law.
– Bojana Kostic, Pen to Paper.
– Maksym Dvorovyi, Digital Security Lab.
– Oleksandr Burmahin, National Council of Television and Radio Broadcasting of Ukraine.
– Nino Macharashvili, ForSet.
– Tamar Kintsurashvili, Media Development Foundation.
– Christoph Schmon, Electronic Frontier Foundation.
– Nina Shengelia, Social Media Council Georgia.
– Elodie Vialle, Independent.
– Artur Papyan, Cyber HUB‑AM.
– Sally Broughton Micova, University of East Anglia.
– Ruslan Mihalevschi, Audiovisual Council of the Republic of Moldova.
– Ana Toskic, Partners Serbia.
– Guy Berger, Independent.

 Commenting on the publication, Kristina Rud, HLEG Coordinator and Public Interest Tech Adviser, IMS, said: “The countries represented in our expert group span very different political, institutional and regulatory contexts – from the Western Balkans to Eastern Europe. Yet they face a shared reality: accession to the EU will bring immediate obligations under the Digital Services Act, and the quality of that transition will depend entirely on the groundwork laid today. Operational readiness is not a checklist to be completed at the last moment – it is a gradual, multi-layered process of institutional development, legal alignment and capacity building. The structures, expertise and trust built during the pre-accession period become the foundations of effective enforcement after accession. In that sense, the work done now is not preparatory – it is constitutive. We offer this document as a practical guide for that work, and as an invitation to all relevant actors to engage with it.”