Source: European Commission

On 26 October 2026 the European Commission announced that it has accepted Temu’s action plan to comply with the Digital Services Act (DSA) and tackle the availability of illegal products online. The plan follows a non-compliance decision from May 2026, in which the Commission found that Temu had failed to comply with its risk assessment obligations and issued a 200 million euro fine.

Five measures to remedy the breach

The action plan focuses on five measures. Temu will carry out a platform-specific risk analysis and use reliable metrics to evaluate how effective its mitigation measures are at reducing the risk of illegal content spreading. The platform will also assess the limitations of its content moderation and analyse whether and how its recommender systems may amplify the spread of illegal goods. Finally, it will examine the influence of intentional manipulation and amplification of illegal items, including sellers exploiting Temu’s features to spread potentially illegal listings.

The company now has four months to conduct an interim risk assessment covering a six month period up to 30 November 2026, to make sure the measures in the plan are actually implemented.

Why this matters beyond Temu

The Commission frames the action plan as proof that the DSA is enhancing consumer protection online and limiting the spread of illegal products in Europe. For any business operating a platform, marketplace, or user generated content in the EU, the message is that risk assessment obligations under the DSA are being enforced with real financial consequences, and that remediation plans are being monitored against deadlines rather than accepted on paper.

DSA and GDPR obligations increasingly overlap with security and infrastructure decisions, from logging and moderation tooling to data residency. If you need help building compliance and risk processes that satisfy European regulators, contact us for professional advice.