Since Meta and TikTok have been asked to respond individually, achieving such harmonisation seems unlikely—unless both researchers and regulators actively push for it. I have high hopes 😉

Researchers need a BASELINE STANDARD OF PUBLICLY ACCESSIBLE DATA: a minimum set of comparable, high-quality data from all platforms, along with robust quality checks to ensure validity.

2) Burdensome tools
The data access tools provided under Article 40(12) are also inadequate. Both Meta and TikTok reportedly supply incomplete data with questionable accuracy.

Researchers need STANDARDISED APPLICATION FORMS and FAIR, TRANSPARENT TERMS ACROSS PLATFORMS. Without them, access to data will remain extremely resource-intensive, discouraging cross-platform research and keeping much of this work in a legal grey area.

For example, both platforms request detailed information about researchers’ qualifications, while Meta even asks for a date of birth and phone number. On top of that, researchers must agree to contradictory or restrictive terms just to apply for data access.

1) Burdensome procedures
In practice, this means that the application processes set up by these platforms may violate the DSA’s provisions. TikTok’s application form reportedly includes around 40 required fields, while Meta’s goes up to 50 - many without connection to the requirements in Art. 40(8)

das Policy Paper:
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