--- title: "DSA average monthly active recipients: what platforms must publish" canonical_url: "https://www.sorena.io/artifacts/eu/digital-services-act/faq/average-monthly-active-recipients" source_url: "https://www.sorena.io/artifacts/eu/digital-services-act/faq/average-monthly-active-recipients" author: "Sorena AI" description: "A grounded FAQ on average monthly active recipients under the EU Digital Services Act, including publication, EU recipient scope, the 45 million VLOP/VLOSE threshold, and evidence records." published_at: "2026-05-09" updated_at: "2026-05-09" keywords: - "DSA average monthly active recipients" - "EU Digital Services Act Article 24" - "VLOP threshold" - "VLOSE threshold" - "active recipients in the Union" - "EU Digital Services Act" - "DSA" - "average monthly active recipients" - "Article 24" - "Article 33" - "VLOP" - "VLOSE" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # DSA average monthly active recipients: what platforms must publish A grounded FAQ on average monthly active recipients under the EU Digital Services Act, including publication, EU recipient scope, the 45 million VLOP/VLOSE threshold, and evidence records. *DSA FAQ* *EU* ## 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. 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. ## 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. Sources for this answer: - [Regulation (EU) 2022/2065 (Digital Services Act)](https://eur-lex.europa.eu/eli/reg/2022/2065/oj/eng?ref=sorena.io) - Article 24(2) sets the publication duty for average monthly active recipients in the Union and Article 24(3) addresses authority requests for calculation explanations and substantiation. - [European Commission - DSA guidance on publishing user numbers](https://digital-strategy.ec.europa.eu/en/library/dsa-guidance-requirement-publish-user-numbers?ref=sorena.io) - Commission guidance identifies Article 24(2), Recital 77, Article 3 definitions, and Article 33 as the main DSA provisions for identifying and counting active recipients. ## 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. Sources for this answer: - [Regulation (EU) 2022/2065 (Digital Services Act)](https://eur-lex.europa.eu/eli/reg/2022/2065/oj/eng?ref=sorena.io) - Article 24(2) supports the six-month publication cadence and Article 24(3) supports the authority-request response expectation. - [European Commission - DSA guidance on publishing user numbers](https://digital-strategy.ec.europa.eu/en/library/dsa-guidance-requirement-publish-user-numbers?ref=sorena.io) - Commission guidance explains the first publication deadline and the practical questions raised by providers about counting active recipients. ## 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. Sources for this answer: - [Regulation (EU) 2022/2065 (Digital Services Act)](https://eur-lex.europa.eu/eli/reg/2022/2065/oj/eng?ref=sorena.io) - Article 33 provides the 45 million threshold, the Commission designation process, the one-year below-threshold termination rule, and the four-month application timing after notification. - [European Commission - Very large online platforms and search engines](https://digital-strategy.ec.europa.eu/en/policies/dsa-vlops?ref=sorena.io) - Commission overview explains that platforms and search engines with more than 45 million monthly EU users are in scope for the DSA's most stringent rules once designated. - [European Commission - Supervision of designated VLOPs and VLOSEs under the DSA](https://digital-strategy.ec.europa.eu/en/policies/list-designated-vlops-and-vloses?ref=sorena.io) - Commission list shows that reported average monthly active-user figures are published with a caveat that they remain without prejudice to Commission assessment of the calculation methodology. ## 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. Sources for this answer: - [Regulation (EU) 2022/2065 (Digital Services Act)](https://eur-lex.europa.eu/eli/reg/2022/2065/oj/eng?ref=sorena.io) - Article 24(3) supports keeping explanations and substantiation for the calculation while excluding personal data from the information supplied. - [European Commission - Supervision of designated VLOPs and VLOSEs under the DSA](https://digital-strategy.ec.europa.eu/en/policies/list-designated-vlops-and-vloses?ref=sorena.io) - Commission designation table illustrates why providers should retain methodology records: listed user numbers are described as provider-reported and without prejudice to Commission methodology assessment. ## Primary sources - [Regulation (EU) 2022/2065 (Digital Services Act)](https://eur-lex.europa.eu/eli/reg/2022/2065/oj/eng?ref=sorena.io) - Binding DSA source for Article 24 publication and authority-response duties, Article 33 VLOP/VLOSE threshold and designation, and Article 42 transparency-report recipient information. - Quote: "average monthly active recipients of the service in the Union" - [European Commission - DSA guidance on publishing user numbers](https://digital-strategy.ec.europa.eu/en/library/dsa-guidance-requirement-publish-user-numbers?ref=sorena.io) - Commission guidance source for practical questions about identifying and counting active recipients and the first Article 24(2) publication deadline. - Quote: "Questions and Answers on identification and counting" - [European Commission - Very large online platforms and search engines](https://digital-strategy.ec.europa.eu/en/policies/dsa-vlops?ref=sorena.io) - Commission overview for the VLOP/VLOSE threshold, six-month user-number update expectation, and examples of obligations triggered after designation. - Quote: "over 45 million users in the EU" - [European Commission - Supervision of designated VLOPs and VLOSEs under the DSA](https://digital-strategy.ec.europa.eu/en/policies/list-designated-vlops-and-vloses?ref=sorena.io) - Commission list showing designated services, average monthly active-user figures, enforcement status, and the caveat that provider-reported figures remain subject to Commission methodology assessment. - Quote: "without prejudice to the assessment by the Commission" ## Topic Guides - [DSA Ads and Recommender Systems: transparency duties, user choice, and evidence](/artifacts/eu/digital-services-act/ads-and-recommender-systems.md): A grounded DSA guide to ad labels, targeting restrictions, recommender parameter disclosure, non-profiling options for VLOPs and VLOSEs, ad repositories, and compliance evidence. - [DSA Applicability Test: classify intermediary services, platforms, marketplaces, VLOPs and VLOSEs](/artifacts/eu/digital-services-act/applicability-test.md): A source-grounded EU Digital Services Act applicability test for classifying intermediary services, hosting services, online platforms, marketplaces, VLOPs and VLOSEs. - [DSA Article 28 minors protection guide for online platforms](/artifacts/eu/digital-services-act/minors-protection.md): EU Digital Services Act guide to Article 28 minors protection: platform scope, child-safety measures, targeted ads limits, recommender controls, and grounded evidence. - [DSA Complaint and Dispute Workflows for Online Platforms](/artifacts/eu/digital-services-act/complaint-and-dispute-workflows.md): Build DSA complaint, appeal, statement-of-reasons, and out-of-court dispute workflows for online platform moderation decisions. - [DSA crisis response for VLOPs and VLOSEs](/artifacts/eu/digital-services-act/crisis-response.md): EU Digital Services Act crisis response guide for VLOPs and VLOSEs: Article 36 Commission decisions, Article 48 crisis protocols, mitigation, governance, requests for information, and records. - [DSA Dark Patterns: interface design checks for online platforms](/artifacts/eu/digital-services-act/dark-patterns.md): Article 25 DSA guidance for reviewing online platform interfaces for deceptive, manipulative, or choice-distorting design patterns. - [DSA Enforcement and Penalties in the EU](/artifacts/eu/digital-services-act/enforcement-penalties-and-investigations.md): How Digital Services Act enforcement works: Commission and Digital Services Coordinator roles, VLOP and VLOSE investigations, fines, periodic penalty payments, and evidence readiness. - [DSA illegal content notices: what must be included?](/artifacts/eu/digital-services-act/faq/illegal-content-notice.md): A grounded FAQ on EU Digital Services Act illegal-content notices: Article 16 notice elements, acknowledgement, decision notices, trusted flagger priority, statements of reasons, and records. - [DSA Marketplace Trader Traceability FAQ](/artifacts/eu/digital-services-act/faq/marketplace-trader-traceability.md): Answer to what EU Digital Services Act Article 30 requires online marketplaces to collect, verify, display, retain, and evidence for trader traceability. - [DSA Marketplace Trader Traceability Guide](/artifacts/eu/digital-services-act/marketplace-trader-traceability.md): EU Digital Services Act guide for online marketplaces collecting, checking, displaying, storing, and evidencing trader traceability information. - [DSA notice and action plus statements of reasons guide](/artifacts/eu/digital-services-act/notice-and-action-plus-statements-of-reasons.md): A grounded Digital Services Act guide for notice intake, moderation decisions, statements of reasons, DSA Transparency Database submission, complaints, appeals, trusted flaggers, and records. - [DSA Notice and Action Workflow for Hosting Services and Online Platforms](/artifacts/eu/digital-services-act/notice-and-action-workflow.md): A grounded DSA notice-and-action workflow covering notice intake, completeness checks, trusted flaggers, decisions, user communications, statements of reasons, appeals, and records. - [DSA recommender transparency FAQ: Article 27 and VLOP options](/artifacts/eu/digital-services-act/faq/recommender-transparency.md): What EU Digital Services Act recommender transparency requires: main parameters, user options, VLOP/VLOSE non-profiling choices, and evidence to keep. - [DSA researcher data access for VLOPs and VLOSEs](/artifacts/eu/digital-services-act/researcher-data-access.md): Article 40 DSA guide to vetted researcher data access for VLOPs and VLOSEs: DSC requests, eligibility checks, amendment grounds, confidentiality, security, and evidence records. - [DSA service tier classifier for platforms, marketplaces, VLOPs and VLOSEs](/artifacts/eu/digital-services-act/service-tier-classifier-workflow.md): Classify a digital service under the EU Digital Services Act as intermediary, hosting, online platform, marketplace, VLOP or VLOSE, with EU recipient-count evidence and obligation outputs. - [DSA statement of reasons FAQ](/artifacts/eu/digital-services-act/faq/statement-of-reasons.md): When DSA statements of reasons are required, what they must contain, when online platforms submit them to the DSA Transparency Database, and what appeal records to keep. - [DSA statement of reasons log workflow for online platforms](/artifacts/eu/digital-services-act/statement-of-reasons-log-workflow.md): Build a DSA statement of reasons log for moderation decisions, Transparency Database submission, complaint links, retention, and QA controls. - [DSA transparency report template fields and cadence](/artifacts/eu/digital-services-act/dsa-transparency-report-template.md): A source-grounded template outline for Digital Services Act transparency reports, covering applicable service tiers, reporting periods, CSV/XLSX format, retention, statement-of-reasons links, and required evidence tables. - [DSA Transparency Reporting Obligations by Provider Tier](/artifacts/eu/digital-services-act/transparency-reporting.md): A grounded guide to EU Digital Services Act transparency reports, active-recipient publication, statements-of-reasons submissions, VLOP/VLOSE reports, templates, cadence, and evidence. - [DSA VLOP and VLOSE Risk Assessments and Mitigation Guide](/artifacts/eu/digital-services-act/risk-assessments-and-mitigation.md): Grounded guide to Digital Services Act systemic risk assessments, mitigation measures, audits, transparency reports, data access, and governance evidence for VLOPs and VLOSEs. - [DSA VLOP Audit Pack Workflow: Risk, Mitigation, Audit, and Transparency Records](/artifacts/eu/digital-services-act/vlop-audit-pack-workflow.md): Build a DSA VLOP or VLOSE audit pack covering Article 34 risk assessments, Article 35 mitigations, independent-audit evidence, transparency reports, data access, and compliance governance. - [DSA VLOP Risk Assessment FAQ: Article 34, Mitigation, Audits](/artifacts/eu/digital-services-act/faq/vlop-risk-assessment.md): What VLOPs and VLOSEs must assess under the EU Digital Services Act, when to reassess, how Article 35 mitigation and annual audit evidence fit together, and what records to keep. - [DSA vs DMA Platform Rules](/artifacts/eu/digital-services-act/dsa-vs-dma.md): Compare the EU Digital Services Act and Digital Markets Act by scope, designation thresholds, obligations, enforcement, evidence, and practical team ownership. - [DSA vs GDPR: online-platform governance and personal-data obligations](/artifacts/eu/digital-services-act/dsa-vs-gdpr.md): Compare the EU Digital Services Act and EU GDPR by scope, ads, recommenders, minors, transparency, complaints, enforcement, and evidence. - [DSA vs P2B Regulation: EU platform obligations compared](/artifacts/eu/digital-services-act/dsa-vs-p2b.md): Compare the EU Digital Services Act with the Platform-to-Business Regulation for platform scope, business-user terms, content moderation, ranking transparency, complaints, enforcement, and evidence. - [DSA vs Terrorist Content Online Regulation: notice-and-action vs removal orders](/artifacts/eu/digital-services-act/dsa-vs-terrorist-content-online-regulation.md): Compare DSA content-governance duties with the EU Terrorist Content Online Regulation removal-order workflow for scope, timing, evidence, authorities, and team ownership. - [EU Digital Services Act checklist for platforms and hosting services](/artifacts/eu/digital-services-act/checklist.md): A grounded DSA checklist for classifying service tiers, notice-and-action, statements of reasons, complaints, transparency reports, ads, recommenders, trader traceability, VLOP/VLOSE duties, and evidence records. - [EU Digital Services Act Compliance Guide](/artifacts/eu/digital-services-act/compliance.md): DSA compliance guide for intermediary services, hosting providers, online platforms, marketplaces, and VLOP/VLOSE teams: obligations, controls, and evidence to keep. - [EU Digital Services Act FAQ: DSA scope, platform duties, VLOPs, reports, and penalties](/artifacts/eu/digital-services-act/faq.md): Concise EU Digital Services Act FAQ covering intermediary-service scope, active-recipient thresholds, illegal-content notices, statements of reasons, trader traceability, recommender transparency, systemic-risk duties, reporting, penalties, and complaints. - [EU Digital Services Act penalties and fines: caps and enforcement roles](/artifacts/eu/digital-services-act/penalties-and-fines.md): DSA penalty caps and enforcement roles: Member State fines, Commission fines for VLOPs and VLOSEs, 1% procedural fines, and 5% periodic penalty payments. - [EU Digital Services Act requirements by service tier](/artifacts/eu/digital-services-act/requirements.md): Overview of DSA obligations for intermediary services, hosting providers, online platforms, marketplaces, VLOPs and VLOSEs, including notices, complaints, ads, transparency reports, audits, data access and enforcement. - [EU Digital Services Act service types and scope](/artifacts/eu/digital-services-act/service-types-and-scope.md): Classify DSA service scope across mere conduit, caching, hosting, online platforms, marketplaces, online search engines, and VLOP/VLOSE threshold duties. - [EU DSA deadlines and compliance calendar: application dates, reporting cycles, and VLOP clocks](/artifacts/eu/digital-services-act/deadlines-and-compliance-calendar.md): Calendar view of grounded EU Digital Services Act dates: full application, user-number publication, VLOP/VLOSE designation clocks, statements of reasons, and transparency reporting cycles. - [EU DSA Transparency Calendar: reporting, SoR database, AMAR updates](/artifacts/eu/digital-services-act/transparency-calendar.md): Build a DSA transparency calendar for annual reports, statement-of-reasons database submissions, active-recipient updates, and VLOP/VLOSE audit touchpoints. - [EU DSA vs UK Online Safety Act: scope, duties, regulator, and evidence](/artifacts/eu/digital-services-act/dsa-vs-uk-online-safety-act.md): Compare the EU Digital Services Act and UK Online Safety Act for platform scope, risk assessments, child protection, transparency, regulators, enforcement, and owners. *Recommended next step* *Placement: before sources* ## 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. - [Open Research Copilot for EU Digital Services Act](/solutions/research-copilot.md): Ask source-linked questions about Article 24 publication, Article 33 designation, and DSA evidence records using the cited sources on this page. - [Talk through implementation](/contact.md): Review your DSA user-number publication, VLOP/VLOSE threshold exposure, and authority-response records with Sorena. --- [Privacy Policy](https://www.sorena.io/privacy) | [Terms of Use](https://www.sorena.io/terms-of-use) | [DMCA](https://www.sorena.io/dmca) | [About Us](https://www.sorena.io/about-us) (c) 2026 Sorena AB (559573-7338). 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