Spanish MEP Leire Pajín (S&D) has asked the European Commission to clarify whether domain name resolution (DNS) services qualify as intermediary services under the Digital Services Act (DSA), and if so, which category they fall into. The question, submitted on 22 June 2026, seeks to resolve legal uncertainty that has arisen from diverging judicial and administrative rulings across Member States on the application of the DSA to DNS services.
The parliamentary question notes that the DSA itself acknowledges the emergence of new technologies that improve online data transmission and findability, but that doubts persist about the legal classification of such services. Pajín specifically asks the Commission to consider whether DNS services are intermediaries under Regulation (EU) 2022/2065, and which subcategory they would belong to—such as mere conduit, caching, or hosting—which determines their liability exemptions and obligations to cooperate with authorities on removing or blocking illegal content.
The MEP also references the AGORA data-sharing platform between Digital Services Coordinators and the Commission, suggesting that the Commission may already have information on how Member States are treating DNS services in practice. The question implies that inconsistent national interpretations could undermine the DSA's uniform application across the single market.
Pajín's query targets a technical but potentially significant gap in the DSA's scope. If DNS services are classified as intermediaries, they would be subject to obligations such as notice-and-action mechanisms, transparency reporting, and cooperation with law enforcement. If not, they would fall outside the DSA's regulatory framework, potentially creating loopholes for illegal content to remain accessible via alternative domain resolution paths.
The Commission is expected to reply within approximately six weeks. Its answer will signal whether it views DNS as a regulated intermediary service or as a purely technical infrastructure layer outside the DSA's remit, with implications for online content regulation, cybersecurity, and the responsibilities of internet infrastructure providers.