MEP Leire Pajín (S&D) has asked the European Commission to clarify whether reverse proxy services qualify as intermediary services under the Digital Services Act (DSA), and if so, under which category they would fall. The question, submitted on 22 June 2026, seeks to resolve legal uncertainty that could affect how these technical services collaborate with authorities to remove or block illegal content.
Reverse proxies sit between users and web servers, improving performance and security. Their legal status under the DSA is unclear, with varying judicial and administrative rulings across Member States. Pajín’s question references the DSA’s own recognition that new technologies have created an increasingly complex online ecosystem, and asks the Commission to use the AGORA data-sharing platform — where Digital Services Coordinators and the Commission exchange information — to inform its answer.
first, whether reverse proxy services are intermediary services under the DSA; second, if so, which of the DSA’s categories (e.g., mere conduit, caching, hosting) they fall into. The answer, expected within roughly six weeks, will signal the Commission’s interpretation of the DSA’s scope and could have significant implications for providers of such services, as well as for national authorities enforcing illegal content removal obligations.
If the Commission classifies reverse proxies as intermediaries, they would be subject to liability exemptions and cooperation duties under the DSA, potentially increasing compliance costs for providers. A negative classification would leave them outside the DSA’s framework, reducing regulatory burdens but also limiting legal clarity for authorities seeking to tackle illegal content. The question highlights a broader tension between technological innovation and regulatory certainty, with stakeholders including reverse proxy service providers, national Digital Services Coordinators, and online platforms that rely on such services.