Plain Language for Digital Rights: Applying ISO 24495-1 to the Bulgarian Communication of the Digital Services Act

The article by Ruslana Margova, titled “Plain Language for Digital Rights: Applying ISO 24495-1 to the Bulgarian Communication of the Digital Services Act,” examines whether the European Commission’s Bulgarian-language communication about the Digital Services Act (DSA) enables citizens not only to access information about their digital rights, but also to find, understand, and use that information effectively. The study applies the international Plain Language standard ISO 24495-1 as its analytical framework.

The paper starts from the premise that having a legal right is not sufficient if citizens cannot understand how to exercise it. The DSA introduces mechanisms related to transparency, content moderation, complaints, redress, and platform accountability, but their practical effectiveness depends partly on how clearly these mechanisms are communicated to ordinary users. The availability of Bulgarian translations therefore does not automatically mean that the information is genuinely accessible.

A central contribution of the study is the application of ISO 24495-1:2023, the first international standard dedicated specifically to Plain Language. The standard was adopted in Bulgaria as BDS ISO 24495-1:2025. Rather than measuring only sentence length or vocabulary difficulty, it evaluates communication according to four user-centred principles: Relevant, Findable, Understandable, and Usable.

The study uses qualitative content analysis of official Bulgarian-language European Commission webpages dealing with the DSA and compares them with their English-language counterparts. It examines their structure, navigation, terminology, information hierarchy, and the extent to which they help users understand and exercise their rights. The analysis focuses on explanatory webpages rather than on the legal text of the DSA itself.

For Relevance, the results are relatively positive. Introductory DSA pages generally explain why the Regulation matters and connect it to users’ rights. More specialised resources, however, tend to focus on regulatory structures and institutional information without sufficiently explaining why that information matters to an ordinary citizen.

For Findability, the Commission’s webpages have a generally coherent structure, but several problems emerge for Bulgarian users. Links do not always preserve the Bulgarian-language setting, specialised pages often have institution-oriented rather than user-oriented titles, and users may need to navigate through several European-level resources before reaching relevant Bulgarian information. The paper therefore concludes that the webpages are structurally organised but only partially satisfy user-centred findability.

Understandability emerges as the greatest challenge. Specialised terms such as Very Large Online Platform (VLOP), Very Large Online Search Engine (VLOSE), Digital Services Coordinator, trusted flagger, and systemic risk are translated into Bulgarian but are not always sufficiently contextualised. The webpages frequently assume prior knowledge of EU digital regulation that first-time users may not possess. The study also notes that some Bulgarian pages are explicitly identified as machine translations, illustrating a broader distinction between translation and genuine localisation. Accurate translation preserves legal content, but user-centred communication additionally requires adapting explanations and information structure to the needs of the target audience.

For Usability, the paper finds that information about rights and complaint mechanisms is available, but it is primarily organised around legal procedures rather than real-life user problems. A citizen is more likely to ask “My content was removed—what can I do?” than to search for a particular legal redress mechanism. The current structure therefore informs users about their rights more effectively than it helps them exercise those rights in practice.

The paper demonstrates an alternative, task-oriented Plain Language approach. For a content-removal scenario, information could begin with the user’s problem—“My content was removed. What can I do?”—and then provide a sequence of concrete actions: check why the content was removed, use the platform’s internal complaint mechanism, and, where necessary, proceed to dispute resolution or the relevant Digital Services Coordinator. This illustrates how all four ISO principles can work together in practical communication design.

A broader finding is the distinction between multilingual availability and user-centred localisation. The Bulgarian pages largely reproduce the structure and terminology of their English counterparts. The paper argues that translation should therefore be viewed as one component of multilingual accessibility, not its final stage. EU-level information could be complemented by nationally adapted guidance that provides direct routes to relevant authorities and organizes information around situations such as content removal, account suspension, or reporting illegal content.

The study also acknowledges important limitations: the assessment was conducted by a single researcher, there was no independent inter-coder validation, and the study did not include empirical testing with Bulgarian users. It also examines only European Commission webpages rather than the broader Bulgarian DSA communication environment. Future research could therefore incorporate comprehension tests, usability studies, interviews, and quantitative readability measures.

Overall, the study finds that the Bulgarian DSA webpages provide comprehensive and legally accurate information but only partially meet the four Plain Language principles. The main barriers are specialised terminology, assumptions about prior knowledge, fragmented navigation, and institution-centred rather than user-centred information design. Its core conclusion is succinct: digital rights can only be effectively exercised when citizens can find, understand, and use the information explaining them.

Suggested citation

Margova, Ruslana. 2026. “Plain Language for Digital Rights: Applying ISO 24495-1 to the Bulgarian Communication of the Digital Services Act.”