§ AI Act · DSA COMPARISON

AI Act vs DSA: Where They Overlap and Conflict

3 overlaps, 0 conflicts and 2 gaps mapped between AI Act and DSA in the Fontvera regulatory corpus.

Summary

AI Act and DSA both apply across European business activity, but they were drafted at different times with different policy goals. This page summarises every article-level crossref between the two in the Fontvera corpus.

3 overlaps mean the same conduct triggers obligations in both regimes — design controls once, document twice. 0 conflicts mean the two regulations push in opposite directions on a specific question. 2 gaps mean one regulation leaves something on a topic the other addresses.

Who this applies to
Compliance teams who need to map a single control framework onto both AI Act and DSA.
Compliance deadline
§ Detail

In depth

Summary statistics

Overlaps: 3 · Conflicts: 0 · Gaps: 2

5 article-level crossrefs catalogued between AI Act and DSA from the Fontvera EU regulatory corpus. Article numbers are verbatim from the underlying obligation_crossrefs table; descriptions are extracted, not paraphrased.

All crossrefs between these regulations

Article (A)Article (B)TypeSeverityDescription
AI Act Art 11DSA Art 14overlaplow[entity affected: provider of high-risk AI systems / provider of intermediary services] Both regulations require entities to maintain and make available technical documentation or terms of conditions
AI Act Art 12DSA Art 15overlapmedium[entity affected: provider of high-risk AI systems / provider of intermediary services] Both regulations mandate the recording and reporting of operational data, such as logs for AI systems or content
AI Act Art 101DSA Art 20overlapmedium[entity affected: provider of general-purpose AI models / provider of online platforms] Both regulations establish procedural safeguards requiring entities to provide opportunities to be heard or hand
AI Act Art ?DSA Art ?gaphigh[entity affected: provider of AI-driven content moderation tools] Neither regulation explicitly harmonizes the liability or specific technical standards for AI systems used by platforms to detect ille
AI Act Art ?DSA Art ?gapmedium[entity affected: provider of generative AI for advertising] While the DSA prohibits manipulative design and the AI Act requires transparency, there is no clear joint obligation for labeling AI-genera

Overlaps explained

No conflict-type crossrefs were catalogued for this pair, but the 3 overlaps below mean a single control can be designed to satisfy both regulations at once. Plan the controls jointly to avoid duplicate effort:

Which regulation takes precedence

EU law does not lay down a universal precedence rule between AI Act and DSA. In practice three resolution approaches apply: lex specialis (the more specific provision wins when both purport to govern the same conduct); regulator guidance (EDPB, EBA, ESMA and the AI Office have all issued joint readings on overlapping articles — check the most recent applicable opinion); and document the choice (when the regulations leave the call to the controller, the audit defence is your written reasoning, not the regulator's silence). Where the corpus surfaces a conflict rather than an overlap, treat that as an escalation path to legal — not a control-design question.

What this means for your compliance team

Treat the 3 overlaps as design opportunities — one control, two regulatory anchors. Treat the 0 conflicts as escalation paths to legal: the regulations themselves don't resolve them, you do, and you document the reasoning. The 2 gaps point at scenarios where one regulation is silent while the other speaks — assume the regulator who has the explicit rule will win.

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§ What Fontvera found

Documents in our corpus

eiopa EU Fetched 2026-04
Opinion on Artificial Intelligence governance and risk management
eurlex EU Fetched 2026-04
EUR-Lex: 32025R0454 (2025-03-07)
ai_office EU Fetched 2026-05
§ Cross-references

Related Fontvera intelligence

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