Online Platform
An online platform is a hosting service that stores and disseminates information to the public at the request of users. Examples include social media networks, video-sharing sites, online marketplaces, and app stores. Under EU law, online platforms have specific transparency and moderation obligations, especially when they facilitate political advertising.
Legal Basis
"Online platform" means a provider of a hosting service that, at the request of a recipient of the service, stores and disseminates information to the public; it does not include services where the dissemination to the public is a minor and purely ancillary feature that is intrinsically linked to another service.
— Article 3(j), Regulation (EU) 2022/2065 (Digital Services Act)
The Digital Services Act (DSA) establishes this definition, which also applies in the context of the Political Advertising Regulation (EU 2024/900).
Why It Matters
Online platforms are central to the dissemination of political advertising in the EU. When a platform publishes political advertisements—whether through paid posts, sponsored content, or boosted messages—it becomes a publisher of political advertising services under Regulation 2024/900. This triggers transparency obligations including clear labelling of ads, providing transparency notices, and maintaining accessible reporting channels for possible breaches.
For platforms hosting political ads, the regulation requires that users can easily identify political content, understand who paid for it, and report missing or incorrect labels. Very large online platforms (VLOPs) with over 45 million monthly users in the EU face additional obligations under the DSA, including systemic risk assessments for electoral processes and enhanced content moderation during election periods.
The platform's role is crucial: it determines what content reaches citizens, how it is ranked and recommended, and whether users can distinguish political persuasion from organic content. These gatekeeping functions make transparency rules essential for fair elections and informed democratic participation.
Key Points
- Online platforms store and disseminate user-generated information to the public, distinguishing them from simple hosting providers or telecommunications services
- Political advertising publishers must ensure ads are clearly labelled and provide transparency information (sponsor, reach, targeting criteria) accessible to users
- Reporting channels for missing or incorrect labels must be free and easily accessible to any user or concerned party
- DSA obligations apply to all online platforms, with stricter rules for very large platforms during electoral periods
- Cross-border provision means platforms established outside the EU are covered if they offer services to EU users
- Not every service qualifies: comments sections in newspapers or purely ancillary features may be excluded if dissemination is minor and intrinsically linked to another service
Online Platform vs. Hosting Service
All online platforms are hosting services, but not all hosting services are online platforms. The key difference is public dissemination: an online platform actively disseminates stored information to the public, while a basic hosting service merely stores data without making it publicly accessible.
For example, cloud storage for private documents is hosting but not a platform. A social media network where users post content visible to others is an online platform. This distinction matters because online platforms face transparency obligations for political advertising, while pure hosting providers typically do not.
Comparison Table:
| Feature | Online Platform | Hosting Service Only |
|---|---|---|
| Public dissemination | Yes, actively facilitates | No, or purely ancillary |
| Political ad labelling required | Yes, when publishing ads | Generally no |
| User-facing transparency | Required by DSA | Limited obligations |
| Examples | Facebook, YouTube, X (Twitter) | Cloud storage, private file hosting |