Porn Platforms & the DSA
What the Risk Assessments Reveal (and what’s missing)
April 2026
Three of Europe’s largest adult platforms (Aylo (Pornhub), Stripchat*, and Xvideos) are legally required under the EU Digital Services Act to publish annual risk assessments. After six months of research, the Digital Intimacy Coalition has released the first independent analysis of what these documents actually say, and where they fall dangerously short.
This is the first in-depth analysis of its kind to read these reports through a sex-positive lens: treating gender-based violence and the over-moderation of consensual sexual expression as equally serious violations of fundamental rights.
The fact sheet
Key figures, the four structural weaknesses, and the full compliance matrix at a glance. Click a page to enlarge it.
Key figures
VLOPs analyzed
Aylo, Stripchat*, Xvideos
structural weaknesses
found across every single assessment
address sexual autonomy
as a fundamental right
comply with AI labelling
Art. 35(1)(k)
What we found
Every platform’s risk assessment shares the same four failures.
Opaque methodology
No platform documents a reproducible process. Scholarship is cited selectively, if at all.
A narrow view of gender-based violence
GBV is treated almost entirely as non-consensual image sharing.
Reputation over user safety
Severity ratings are unsubstantiated, and in several cases, commercial interest appears to shape risk classification more than evidence does.
Unproven mitigation
Automated filtering is cited as a solution but never demonstrated. AI-generated content is barely mentioned. There is no public data on moderator training or welfare.
Not one platform meets Article 34(2) or Article 35(1)(k) of the DSA. Not one engages with the fundamental tension between sexual autonomy and gender equality; a tension the EU Charter of Fundamental Rights obliges them to confront.
Why this matters
The Digital Intimacy Coalition continues to strive to be an independent watchdog for the adult industry that holds it to the highest standard of accountability: one willing to hold platforms accountable both when they fail to prevent gender-based violence, and when they over-moderate consensual sexual expression under the guise of safety.
Both are fundamental rights issues. Regulators have only been looking at one.
The task force
Carlotta Rigotti
Legal scholar, Leiden University
Specializes in law, gender, and technology, focusing on the DSA and its implications for online sexual rights.
Isotta (Izzy) Rossoni
Researcher & practitioner, sex work and migration
Combines a decade of field experience with academic insight from her PhD work at Leiden University.
Paige Collings
Senior Speech & Privacy Activist, EFF
Investigates how surveillance and platform moderation impact marginalized communities.
Riley Wong
Principal, Emergent Research
Explores privacy, governance, and consent infrastructures for vulnerable communities, drawing from experience at MIT, Google, and ProPublica.
Nicola Döring
Professor of Media Psychology, TU Ilmenau
Studies sexuality and media, with recent publications on adolescent exposure to pornography and deepfake abuse.
Coordination & supervision
Dominic O'Regan
DIC's Working Group Coordinator
Ana Ornelas
DIC's Advocacy Officer
Get the full picture
The 2-page fact sheet
Key figures, structural findings, and the compliance matrix at a glance.
Download the fact sheetThe full 50-page report
Six months of research, drawing on contributions and feedback from a network of 90+ organisations.
Download the full report*Stripchat has since lost its VLOP designation, after its reported user numbers fell below the DSA threshold. This analysis reflects its legal status at the time the report was researched and written.