Roblox's EU Digital Services Act Transparency Report (2025) Is Live

Roblox has published its EU Digital Services Act transparency report for 2025. The report covers Roblox's content moderation activity for 1 January – 31 December 2025, including notices received and actions taken across EU services. Alongside it, Roblox also published its Terrorist Content Online (TCO) transparency report for the same period.

I owned end-to-end delivery: scoping data requirements against Article 15 obligations, building the cross-functional production workflow across Legal, Policy, and Engineering, and driving on-time publication.

Roblox is not a VLOP, so the report is an annual filing under Article 15 rather than the semi-annual requirement under Article 42. The practical difference, annual cadence, no bi-annual breakdown requirement, shapes the production workflow considerably. The Article 15 data requirements are still non-trivial, particularly the breakdown of own-initiative moderation actions by content category and the documentation of automated tool use, but the timeline and data shape are more manageable than the Article 42 VLOP obligations.

A separate post covers what EU DSA transparency reporting actually requires for both Article 15 platforms and VLOPs, including what Article 42 adds and what that means for reporting infrastructure.