DSA FAQEU

DSA average monthly active recipients publication and threshold FAQ

Average monthly active recipients is the DSA user-number figure that online platforms and online search engines publish for recipients in the Union.

Use this FAQ to separate the public Article 24 publication duty from VLOP/VLOSE threshold analysis, authority requests, transparency reporting, and the evidence needed to explain the number.

Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Questions
4

Structured answer sets in this page tree.

Primary sources
4

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

Under the EU Digital Services Act, providers of online platforms and online search engines publish information on the average monthly active recipients of each service in the Union. The figure matters because Article 33 uses average monthly active recipients in the Union to identify services that may be designated as very large online platforms or very large online search engines.

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4 of 4 questions
Question 1

What does average monthly active recipients mean under the DSA?

For this FAQ, average monthly active recipients means the Article 24(2) user-number publication for an online platform or online search engine: information on the average monthly active recipients of the service in the Union, calculated as an average over the past six months.

The relevant population is not worldwide users. The DSA text and Commission guidance frame the obligation around active recipients of the service in the Union, and the Commission guidance links that publication to Article 24(2), Recital 77, DSA definitions in Article 3, and the VLOP/VLOSE designation rule in Article 33.

  • Measure and publish per online platform or online search engine, not as a single corporate group total.
  • Keep the service boundary clear where one product contains multiple platform, search, retail, marketplace, or third-party-content surfaces.
  • Do not treat a public figure as final proof of non-designation; Article 33 allows the Commission to assess reported data, requested information, or other information available to it.
  • Do not publish personal data as part of the Article 24 calculation support; Article 24(3) says requested calculation substantiation must not include personal data.
Citations
Question 2

When and where must the number be published?

Article 24(2) required providers to publish the first information by 17 February 2023 and to update it at least once every six months thereafter. The publication must be in a publicly available section of the online interface for each online platform or online search engine.

The publication duty is separate from authority-response duties. Under Article 24(3), the Digital Services Coordinator of establishment or the Commission may request the published information updated to the moment of the request, and may require additional calculation information, explanations, and substantiation about the data used.

  • Retain the public URL or interface location where the number was published.
  • Record the six-month measurement period used for the average.
  • Record when the figure was published or updated.
  • Keep a response pack that can be sent without undue delay if the Digital Services Coordinator of establishment or the Commission asks for updated information or substantiation.
  • Separate the public number from non-public calculation support, especially where that support contains sensitive operational data.
Citations
Question 3

How does the number affect VLOP and VLOSE designation?

Article 33 applies the very large online platform and very large online search engine regime to online platforms and online search engines with average monthly active recipients in the Union equal to or higher than 45 million, once designated by the Commission.

Designation is a Commission decision. The Commission can base the decision on Article 24(2) data reported by the provider, information requested under Article 24(3), or other information available to it. If designated, the additional VLOP/VLOSE obligations apply from four months after notification to the provider. The Commission terminates a designation if the service remains below the threshold for an uninterrupted period of one year.

  • Treat 45 million as the Article 33 threshold for average monthly active recipients in the Union, not as a global user threshold.
  • Escalate services that are near, at, or above the threshold before publication so legal, data, and platform leads can review the basis for the figure.
  • Keep a record of any Commission or Digital Services Coordinator correspondence about the number.
  • For designated services, connect the figure to VLOP/VLOSE obligations such as systemic risk assessment, independent audit, data access, recommender-system choices, and advertisement repository obligations.
  • For designated services, Article 42 also requires transparency reports to include average monthly recipients of the service for each Member State.
Citations
Question 4

What evidence should support the published number?

The DSA does not require teams to publish their full internal calculation workbook on the public page. It does, however, let the Digital Services Coordinator of establishment and the Commission ask for explanations and substantiation about the calculation and the data used, without personal data.

A defensible evidence record should therefore explain the service boundary, the Union recipient population, the six-month averaging period, the data sources used, the assumptions applied, the publication location, and the authority-response owner. Keep methodology caveats visible in the internal record rather than turning them into unsupported precision in the public copy.

  • Service name, provider entity, and whether the service is an online platform, online search engine, or both.
  • Union-recipient inclusion rule used by the data team and any known country or Member State limitations in the dataset.
  • Six-month period used for the average and the date the figure was generated.
  • Source systems, query versions, data-quality checks, and reviewers who approved the number.
  • Known exclusions, deduplication assumptions, or split-service assumptions, stated without inventing a universal DSA formula.
  • Public interface URL, publication date, update history, and copies of any authority requests or responses.
  • Confirmation that substantiation prepared for authorities does not include personal data.
Citations
Recommended next step

Use the AMAR record to connect publication, threshold review, and authority response

Sorena can help turn the DSA average monthly active recipients question into a source-cited publication record, threshold review, and evidence pack for legal, data, and platform teams.

Primary sources

References and citations

eur-lex.europa.eu
Referenced sections
  • Article 24(3) supports keeping explanations and substantiation for the calculation while excluding personal data from the information supplied.
"explanations and substantiation in respect of the data used"
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