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 covers recipients in the Union and goes beyond registered accounts. Recital 77 treats recipients as active when they engage with the service at least once during the period, including by being exposed to information disseminated on an online platform, providing information for dissemination, or submitting a query to an online search engine. Consumers, traders, advertisers, and users who are not registered can therefore be relevant to the service-specific count.
The DSA does not prescribe one universal analytics query in Article 24. Providers should document how their data identifies active recipients in the Union, avoids unsupported precision, and produces a six-month average for the particular platform or search service.
- 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 use login, account creation, or a completed transaction as the only activity test when unregistered recipients can be exposed to disseminated information or use the search service.
- 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- Do not publish personal data as part of the Article 24 calculation support; Article 24(3) says requested calculation substantiation must not include personal data.
What is the DSA average monthly active recipients figure?
It is the information that providers covered by Article 24(2) publish about the average monthly active recipients of the service in the Union, calculated over the past six months. Qualifying micro and small online-platform providers can fall within Article 19's exclusion, but Article 24(3) can still support an authority request for current recipient information and substantiation.
Article 24(2) sets the publication duty, Article 24(3) addresses authority requests for calculation explanations and substantiation, and Recital 77 explains the forms of service engagement relevant to identifying active recipients.
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.