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) | Type | Severity | Description |
|---|---|---|---|---|
| AI Act Art 11 | DSA Art 14 | overlap | low | [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 12 | DSA Art 15 | overlap | medium | [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 101 | DSA Art 20 | overlap | medium | [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 ? | gap | high | [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 ? | gap | medium | [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:
- AI Act Art 12 vs DSA Art 15 (medium severity) — [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 moderation statistics for platforms, to facilitate oversight and accountability.
- AI Act Art 101 vs DSA Art 20 (medium severity) — [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 handle complaints effectively before final decisions or fines are imposed.
- AI Act Art 11 vs DSA Art 14 (low severity) — [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 in a clear, accessible, and machine-readable format to ensure transparency and compliance verification.
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.
Related Fontvera pages
- ai act art 17 provider obligations
- ai act art 70 commission obligations
- ai act authorized representative
- ai act automotive
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