Undefined "without undue delay" timeframe for SoR submission under Article 24(5) DSA

Determine whether the upload delays between moderation decisions and the submission of Statements of Reasons to the DSA Transparency Database comply with Article 24(5) of Regulation (EU) 2022/2065 requiring submission "without undue delay," in the absence of defined norms specifying acceptable delay thresholds.

Background

Article 24(5) DSA mandates that platforms submit SoRs to the Commission-managed Transparency Database without undue delay. The authors measure upload delays and note significant variation across platforms, which may be affected by automation or batching of submissions.

Because the DSA provides no explicit norms defining acceptable delay thresholds, the authors explicitly state that compliance cannot presently be ascertained—leaving an open question about how to evaluate observed upload delays against the "without undue delay" requirement.