The Digital Services Act (DSA) introduces a risk-based regulatory framework for very large online platforms (VLOPs) and search engines (VLOSEs) requiring them to identify, assess and mitigate systemic risks as well as to report on their efforts annually. In turn, the European Board for Digital Services must publish an annual overview of the most prominent and recurrent systemic risks, as well as the related mitigation practices. This paper critically examines the Board’s first report, arguing that, in its current form, it largely remains a descriptive compilation of outputs and therefore fails to deliver on the risk-based approach set out in the DSA.The critical examination begins with an assessment of the foundations of the Board’s report. By focusing on how the report uses and documents its sources, it becomes apparent that there is no clear mapping between specific sources and particular claims. This asymmetry hinders transparency, making it difficult to understand how different types of evidence inform the report’s findings.The paper then moves on to the identification of systemic risks. While the DSA considers both actual and foreseeable negative effects, the Board limits its report to risks that have already materialised. This narrows the framework's intended anticipatory function. Drawing on risk assessments provided by social media platforms, the paper argues that including the assessment of systemic risks, rather than just their identification, would facilitate cross-platform comparisons. By failing to examine the prominence and recurrence of systemic risks across services or Member States, the Board is missing an opportunity to fulfil its mandate.Regarding mitigation measures, the paper highlights that the report’s catalogue of measures suggested by providers and CSOs does not evaluate their reasonableness, proportionality, or effectiveness. This neglects to identify 'best or even good practices', despite this being required by the DSA. Furthermore, the paper showcases how the report’s disclaim of any assessment of whether platforms comply with their obligations limits its added value beyond synthesising information already made public by digital services, CSOs and academia.The paper concludes that future versions of the Board’s annual report should shift from summarising to examining to allow for more insights on systemic risks and their mitigation measures.
