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Across 6 modules • Updated May 9, 2026
Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
DSA average monthly active recipients: what platforms must publish

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  • Do not publish personal data as part of the Article 24 calculation support; Article 24(3) says requested calculation substantiation must not include personal data.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
DSA average monthly active recipients: what platforms must publish

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
DSA average monthly active recipients: what platforms must publish

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.
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DSA average monthly active recipients: what platforms must publish

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.
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DSA illegal content notices: what must be included?

What must a DSA illegal-content notice contain?

Article 16 requires providers of hosting services to offer easy-to-access, user-friendly electronic mechanisms for notices about specific items of information that a person or entity considers illegal content.

A notice should be treated as an Article 16 notice only when it is precise enough to identify the content and substantiated enough to let the provider assess the alleged illegality without turning the intake queue into a general monitoring exercise.

  • Capture the reasoned explanation of why the notifier alleges the information is illegal content.
  • Capture the exact electronic location, such as the URL or URLs, plus any content-type-specific details needed to identify the item.
  • Capture the notifier's name and email address unless the Article 16 exception for certain child sexual abuse or exploitation offences applies.
  • Capture the notifier's statement that they believe, in good faith, that the information and allegations are accurate and complete.
  • Record whether the notice is sufficiently precise and adequately substantiated, because only sufficiently specific notices can create actual knowledge or awareness for the specific item.
Citations
DSA illegal content notices: what must be included?

What must happen after the notice is submitted?

If the notice contains the notifier's electronic contact information, the hosting service must confirm receipt without undue delay and later notify the notifier of the decision on the reported information, including available redress routes.

If automated means are used for processing or decision-making, that use must be disclosed in the decision notification. If the provider restricts content because it is illegal or incompatible with terms, Article 17 may also require a clear and specific statement of reasons to the affected recipient.

  • Send a receipt acknowledgement without undue delay when electronic contact details are available.
  • Decide the notice in a timely, diligent, non-arbitrary, and objective manner.
  • Tell the notifier the decision and redress possibilities without undue delay.
  • Tell the notifier when automated means were used for processing or decision-making.
  • When restricting content, prepare the Article 17 statement of reasons for the affected recipient, including restriction type, facts and circumstances, legal or contractual ground, automation use where applicable, and redress information.
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DSA illegal content notices: what must be included?

How do trusted flaggers and records change the workflow?

A trusted flagger notice is still submitted through the Article 16 mechanism, but Article 22 requires online platforms to give priority to notices from trusted flaggers acting within their designated area of expertise and to process and decide them without undue delay.

Trusted flagger status does not transfer the moderation decision to the flagger. The Commission explains that trusted flaggers notify platforms of content they consider illegal, while providers remain responsible for deciding on notices and removing content where justified.

  • Tag whether the notifier is a designated trusted flagger and whether the notice falls within the flagger's area of expertise.
  • Route qualifying trusted flagger notices for priority processing and decision without undue delay.
  • Keep support for any escalation to the awarding Digital Services Coordinator when a trusted flagger submits a significant number of insufficiently precise, inaccurate, or inadequately substantiated notices.
  • For transparency reporting, preserve counts of Article 16 notices by type of alleged illegal content, trusted flagger notices, actions taken under law versus terms, automated processing, and median action time.
  • For online platforms, preserve statement-of-reasons submission status and ensure submissions to the Commission database do not contain personal data.
Citations
DSA Marketplace Trader Traceability

What does DSA marketplace trader traceability require?

For an online marketplace in scope of Article 30, a trader should not be able to promote messages about products or services, or offer products or services to consumers located in the Union, until the platform has obtained the required trader information.

The marketplace also has to make best efforts to assess whether the information is reliable and complete before the trader uses the service. That assessment can use freely accessible official databases or online interfaces made available by a Member State or the Union, or supporting documents from reliable sources requested from the trader.

  • Collect the trader's name, address, telephone number, and email address where applicable.
  • Collect a copy of the trader's identification document or qualifying electronic identification.
  • Collect payment account details and, where applicable, trade-register details and registration number or equivalent identifier.
  • Collect the trader's self-certification committing to offer only products or services that comply with applicable Union law.
  • Block marketplace use for EU consumer offers until the Article 30 information has been obtained and checked for reliability and completeness through best efforts.
Citations
DSA Marketplace Trader Traceability

What must be visible to consumers?

Article 30 separates internal collection from consumer-facing disclosure. The marketplace does not publish every collected item, but it must make the trader's name and contact information, trade-register information where applicable, and the trader's compliance self-certification available to recipients of the service in a clear, easily accessible, and comprehensible way.

The disclosure belongs at least on the marketplace interface where the product or service information appears. Hiding the trader's identity until after checkout is the type of presentation risk the DSA is designed to avoid.

  • Show the trader name, address, telephone number, and email address in the product or service flow where consumers can find it before buying.
  • Show the trade register and registration number or equivalent identifier when the trader is registered in such a register.
  • Show the trader's self-certification that products or services offered through the marketplace comply with applicable Union law.
  • Do not expose identification documents or payment account details to consumers unless another applicable law requires disclosure.
Citations
DSA Marketplace Trader Traceability

What should the marketplace do when information is missing or unreliable?

If the marketplace has sufficient indications or reason to believe that Article 30 trader information is inaccurate, incomplete, or not up to date, it must ask the trader to remedy the problem without delay or within the period set by Union and national law.

If the trader does not correct or complete the information, the marketplace must swiftly suspend the service for that trader in relation to products or services offered to consumers located in the Union. A refusal or suspension decision also connects to the DSA complaint routes available to the trader.

  • Log the signal that made the trader data appear inaccurate, incomplete, or stale.
  • Send a remediation request that identifies the exact missing or defective Article 30 field.
  • Pause or prevent EU consumer offers where the required information is not supplied or corrected.
  • Keep evidence of the request, trader response, suspension decision, and any complaint handling.
Citations
DSA Marketplace Trader Traceability

How do Article 31 and Article 32 connect to traceability?

Trader traceability should be implemented together with Article 31 marketplace interface controls. The interface must let traders provide required pre-contractual, compliance, and product safety information, including product or service identification, trader signs such as a trademark or logo, and applicable labelling and marking information.

After a trader is allowed to offer products or services, the marketplace must make reasonable efforts to randomly check official, freely accessible, machine-readable databases or interfaces to see whether offered products or services have been identified as illegal. If the marketplace becomes aware that an illegal product or service was offered, Article 32 requires consumer information where contact details are available, or public notice where they are not.

  • Design listing forms so traders can provide product or service identification, economic-operator details, trader signs, and applicable labelling or marking information.
  • Before listing, make best efforts to assess whether traders have provided the Article 31 information.
  • After listing, make reasonable random checks against official accessible databases or interfaces for illegal products or services.
  • When an illegal product or service is identified, keep evidence of affected consumers, trader identity, notices sent, public notice if needed, and redress information.
Citations
DSA Marketplace Trader Traceability

What evidence should teams keep?

The useful evidence is the proof that the marketplace actually enforced Article 30 in seller onboarding and live seller maintenance. Keep the collected trader data securely, document how reliability and completeness were assessed, and tie each trader status change to the relevant product or service flow.

Article 30 requires secure storage during the contractual relationship and for six months after it ends, followed by deletion. Disclosure to third parties should be limited to cases required by applicable law, including DSA orders and competent-authority or Commission orders.

  • Seller onboarding record with each Article 30 field, collection timestamp, source, verifier, and result.
  • Reliability check evidence, such as official database lookup result, electronic identification check, or supporting document request and response.
  • Consumer-facing disclosure screenshot or rendered-page capture showing the trader information on the product or service interface.
  • Issue log for incomplete, inaccurate, or outdated trader information, including remediation request, deadline, suspension, reinstatement, and complaint handling.
  • Retention and deletion record showing secure storage through the trader relationship and deletion after the six-month post-relationship period.
Citations
DSA recommender transparency FAQ: Article 27 and VLOP options

What does DSA Article 27 require for recommender system transparency?

Article 27 applies to providers of online platforms that use recommender systems. The DSA defines a recommender system as a fully or partly automated system that suggests information, prioritises it, or determines the relative order or prominence of information in the platform interface.

The platform must set out, in its terms and conditions and in plain, intelligible language, the main parameters used by the recommender system and any options recipients have to modify or influence those parameters.

  • Identify every recommender surface: feed, search results, marketplace ordering, content suggestions, ranking modules, or other interface areas that suggest or prioritise information.
  • Describe the most significant criteria used to determine what information is suggested to a user.
  • Explain why those parameters have their relative importance; do not replace this with an unexplained formula, model name, or generic personalization statement.
  • List the user options that can modify or influence the main parameters, or state clearly when no such option is offered for that recommender surface.
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DSA recommender transparency FAQ: Article 27 and VLOP options

What user controls must be available for DSA recommender choices?

Article 27 distinguishes between disclosure of options and in-product functionality. If several options are available for a recommender system that determines the relative order of information, the platform must let the recipient select and modify the preferred option at any time.

That control must be directly and easily accessible from the specific part of the online interface where information is being prioritised. A buried account setting is weak evidence if the ranking choice is presented somewhere else.

  • Map each terms-and-conditions option to the exact UI control where the recipient can select or change it.
  • Record whether the control changes ranking order, recommendation source, personalization settings, chronological ordering, popularity ordering, location, language, seller, or another main parameter.
  • Keep screenshots or product specs showing the control in the interface section where prioritised information appears.
  • Retest the disclosure after recommender releases, ranking-signal changes, UI redesigns, or changes to terms and conditions.
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DSA recommender transparency FAQ: Article 27 and VLOP options

What extra recommender choice applies to VLOPs and VLOSEs?

Article 38 adds a separate requirement for providers of very large online platforms and very large online search engines that use recommender systems. In addition to Article 27, they must provide at least one option for each recommender system that is not based on profiling under the GDPR definition referenced by the DSA.

The Commission describes VLOPs and VLOSEs as platforms or search engines with equal to or higher than 45 million monthly users in the EU once designated. For those designated services, the recommender inventory should show each recommender system and the matching non-profiling option.

  • Confirm whether the service is designated as a VLOP or VLOSE before applying Article 38 as an extra obligation.
  • For each recommender system, identify the default option, any alternative options, and the option that is not based on profiling.
  • Check that the non-profiling choice is not limited to one surface if multiple recommender systems are used.
  • Keep product and legal sign-off that the option described as non-profiling is implemented consistently in the live ranking service.
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DSA recommender transparency FAQ: Article 27 and VLOP options

What evidence should teams keep for DSA recommender transparency?

Keep enough evidence to prove that the public disclosure, the live user interface, and the recommender implementation describe the same system. This is especially important for VLOPs and VLOSEs because DSA risk assessment, mitigation, audit, and data-access provisions can require explanations of algorithmic-system design, logic, functioning, and testing.

The evidence record should avoid invented scoring formulas. Use the real product documentation: criteria that matter most, reasons those criteria matter, UI choices available to recipients, and release records showing when the disclosure changed.

  • Recommender inventory with surface name, owner, recipient group, ranking objective, main criteria, and whether the surface determines relative order or prominence.
  • Terms-and-conditions extract showing the Article 27 main-parameter explanation and the options to modify or influence those parameters.
  • UI screenshots, design specs, or QA evidence showing where each choice is directly available to recipients.
  • For VLOPs and VLOSEs, evidence for the Article 38 non-profiling option for each recommender system and testing records for algorithmic changes.
  • Change log tying recommender releases, terms updates, and interface changes to legal, product, and data-science review.
Citations
DSA statement of reasons

When is a DSA statement of reasons required?

A statement of reasons is triggered by the moderation decision, not by the label a team gives the workflow. Article 17 applies to providers of hosting services when they impose one of the listed restrictions because information provided by a recipient of the service is considered illegal content or incompatible with the provider's terms and conditions.

The covered restrictions include removing, disabling access to, demoting, or otherwise restricting visibility of specific information; suspending, terminating, or otherwise restricting monetary payments; suspending or terminating all or part of the service; and suspending or terminating the recipient's account.

Article 17 applies only where the provider knows the relevant electronic contact details, and it applies at the latest from the date the restriction is imposed. It does not apply to deceptive high-volume commercial content, and it does not apply to orders covered by Article 9.

  • Trigger: a hosting-service restriction based on illegal content or terms-and-conditions incompatibility.
  • Recipient: any affected recipient of the service whose relevant electronic contact details are known.
  • Timing: provide the statement at the latest when the restriction is imposed.
  • Exclusions to check: deceptive high-volume commercial content and Article 9 orders.
Citations
DSA statement of reasons

What must the statement contain?

Article 17 requires enough detail for the affected recipient to understand the decision and exercise available redress rights. The statement should identify the moderation measure, the territorial scope and duration where relevant, the facts and circumstances relied on, and whether the decision followed an Article 16 notice or voluntary own-initiative investigation.

If automated means were used, the statement should say so where applicable, including whether the moderated content was detected or identified using automated means. If the ground is alleged illegality, cite the legal ground and explain why the information is illegal on that ground. If the ground is terms incompatibility, cite the contractual ground and explain why the information conflicts with it.

Redress information is part of the statement itself. For platform decisions, that means the recipient-facing notice should connect the user to the internal complaint-handling route where available, out-of-court dispute settlement where applicable, and judicial redress.

  • Decision type: removal, disabling access, demotion, visibility restriction, payment restriction, service restriction, or account restriction.
  • Scope and duration: territory and time period where relevant.
  • Basis: facts, circumstances, notice source or own-initiative review, and legal or contractual ground.
  • Automation: whether automated means were used where applicable.
  • Redress: clear, user-friendly complaint, out-of-court dispute settlement, and court options where applicable.
Citations
DSA statement of reasons

What changes for online platforms and the Transparency Database?

The DSA Transparency Database does not collect every hosting-service statement of reasons. The Commission FAQ explains that it collects statements of reasons from online platforms, which are a subset of hosting services that store user-provided information and disseminate it publicly, such as online marketplaces, app stores, or social networks.

For online platforms, Article 24(5) requires submission of the Article 17 decisions and statements of reasons to the Commission without undue delay for inclusion in a publicly accessible, machine-readable database. The submitted information must not contain personal data.

The Commission FAQ says redress options are not included in the public database because they are relevant only for the addressee of the statement of reasons. Operationally, keep the recipient-facing statement with redress information separately from the public database payload, and keep a personal-data removal check before submission.

  • Determine whether the service is an online platform, not only a hosting service.
  • Submit Article 17 decisions and statements of reasons to the Commission without undue delay where Article 24(5) applies.
  • Remove personal data from the database submission.
  • Do not rely on the public database record as the full recipient notice, because redress options are not published there.
  • Use the Commission onboarding, sandbox, API, webform, and batch API paths where applicable to the provider's submission volume.
Citations
DSA statement of reasons

What appeal, complaint, and record links should the workflow preserve?

For online platforms, Article 20 requires an effective internal complaint-handling system for at least six months after the recipient is informed about covered moderation decisions. Complaints must be handled in a timely, non-discriminatory, diligent, and non-arbitrary manner, and complaint decisions must be supervised by appropriately qualified staff rather than made solely by automated means.

Users can also turn to certified out-of-court dispute settlement bodies for covered platform moderation disputes, without losing the ability to go to court. The Commission's dispute-settlement page states that users may select any certified body whose expertise covers the dispute and whose language coverage fits the case.

Keep records that let reviewers connect the original moderation decision, the recipient-facing statement, the Transparency Database submission where required, and any complaint or dispute outcome. The Commission database FAQ also gives retention context for public database access: statements become available from the following day after successful insertion, search retains them for six months, daily dumps retain them for 18 months, and dashboard aggregate statistics cover the last five years.

  • Store the delivered recipient statement and delivery timestamp.
  • Store the moderation action, legal or contractual basis, facts and circumstances, automation flag, scope, duration, and redress text.
  • For online platforms, store the database submission status, submission channel, payload version, personal-data removal check, and any submission errors.
  • Store internal complaint intake, review owner, reasoned outcome, reversal if any, and notice of out-of-court dispute settlement options.
  • Store out-of-court dispute settlement body, dispute scope, language, outcome, implementation decision, and related fee handling where relevant.
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