Very large, largely silent: how three pornography-hosting platforms assess their governance of sexual content under the Digital Services Act

In 2023, the European Commission designated Aylo (Pornhub.com), Stripchat, and XVideos as very large online platforms under the Digital Services Act, subjecting them to binding obligations to identify, assess, and mitigate systemic risks. In 2025, these platforms submitted their first risk assessment reports to the European Commission. This article offers a systematic and critical analysis of these reports from a sex-positive, rights-based perspective – treating both non-consensual sexual content and the suppression of consensual sexual content as systemic risks. The analysis reveals four recurring limitations: methodological opacity; a narrow conceptualization of risk that underestimates technology-facilitated violence against women; structural marginalization of performers and content creators from governance processes; and minimal civil society engagement. All three assessments approach sexual content governance almost exclusively through a harm-prevention lens, remaining silent on the freedoms at stake. The article concludes with recommendations arguing that effective governance must hold protection and freedom in productive tension.