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Deloitte Advisory, S.L.

Realización de auditorías de cuentas económicas, financieras, informáticas, de transacciones y saldos en internet, de gestión y operativas para cualquier persona física o jurídica.

Lobbying Activity

Meeting with Markus Ferber (Member of the European Parliament)

21 Oct 2025 · SIU

Meeting with Antti Timonen (Cabinet of Executive Vice-President Henna Virkkunen), Xavier Coget (Cabinet of Executive Vice-President Henna Virkkunen)

30 Sept 2025 · Eligibility to EU funding.

Meeting with Anne Simon (Head of Unit Health Emergency Preparedness and Response Authority)

19 Mar 2025 · Crisis management solutions Stock pile management tool

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union) and

23 Jan 2025 · Physical meeting - Exchange of views on proposals and future developments in the field of customs and taxation (direct and indirect)

Meeting with Nicolás Pascual De La Parte (Member of the European Parliament)

3 Dec 2024 · Deloitte priorities

Meeting with Nicolás Pascual De La Parte (Member of the European Parliament)

26 Sept 2024 · Presentation EU security and defence

Meeting with Nicolás Pascual De La Parte (Member of the European Parliament)

18 Sept 2024 · Deloitte priorities

Response to Performance of independent audits provided for in the Digital Services Act

2 Jun 2023

On behalf of Deloitte , we are pleased to provide feedback on this draft Delegated Act (DA) concerning the performance of independent audits. At the outset, we note that Article 37 Independent Audit is a key provision for the Digital Services Act (DSA). Independent audit can provide transparency and accountability that facilitates enforcement of the DSA, and will also support the digital services industry to establish and progressively enhance the industry benchmarks for good practice. As such, ensuring that the DSA independent audit requirement is effective is essential for the long-term operational success of this legislation. However, there are fundamental concerns in the approach laid out by the DA which work against its success. Some of these persist from the DSA itself, and others have been introduced by the DA. In summary, we consider the following to be critical issues which have considerable impact on auditing organisations' capacity to provide an effective independent audit in respect to the DSA: 1. The text of the DSA does not provide clear established criteria against which to assure, and neither the DA nor the DSA provide or identify any other sources of criteria against which to assure. In the absence of this criteria, auditing organisations can only assure against the criteria advanced by each individual audited provider. We note that this will produce audits that differ from one another to a significant degree, especially because there is a lack of commonly established criteria across the digital services industry. 2. Noting the lack of clear established criteria, the DA seems to allow or even expect auditing organisations to formulate their own criteria against which to assure. This is not tenable. Among other issues, it would critically undermine the independence of the auditing organisation. 3. The DA does not prescribe an assurance standard by which the independent audit should be performed. As a result, auditing organisations may follow different assurance standards, or even take an ad hoc approach. Again, this will produce audits that are inconsistent and largely incomparable. 4. The proposed DA template for the audit report deviates from a market-recognised assurance report to a significant degree. It prescribes the inclusion of personal information, which we consider to be unjustified. It also indicates, but does not make clear, that a significant amount of qualitative and explanatory information may need to be included in the template. This may lead to inconsistency between reports by providers, and may make the template less clear and useful for users. 5. The DA framework by which auditing organisations should reach their audit opinion can be contradictory in its instructions. For example, around the level of procedures that the auditing organisation must perform, and also, whether auditing organisations should issue a negative or positive with comments audit conclusion if there is a period of non-compliance within the audit period. We also note the following practical matters arising from the DA which may negatively impact the usefulness of the DSA independent audit: 6. The framework by which auditing organisations should reach an overall audit opinion is disproportionate. An overall negative audit opinion may follow from a single instance of non-compliance for a single obligation for a brief period within the audit period. This could lead to conclusions that are harsh, and give the impression of parity between minor and major non-compliance. 7. The level of assurance (reasonable assurance throughout the audit period) is high for a first-year audit of a complex new law like the DSA, especially with very short timeframes between enactment and coming into force. Please find attached our reply and an appendix providing further detail on our concerns and offering solutions that may support an effective DSA audit process in both the short and long term. Pablo Zalba Mark Cankett
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Meeting with Nathalie De Basaldua (Cabinet of Commissioner Mairead Mcguinness)

3 Feb 2022 · Audit reform

Meeting with Marco Buti (Director-General Economic and Financial Affairs)

22 Feb 2018 · Economic outlook