Very Large Online Platform (VLOP)
A Very Large Online Platform (VLOP) is an online platform that has an average of 45 million or more monthly active users in the EU. VLOPs face stricter rules under the Digital Services Act (DSA), including obligations to assess and mitigate systemic risks, conduct independent audits, and provide greater transparency. Examples include major social media platforms, marketplaces, and video-sharing services.
Legal Basis
"A provider of an online platform shall be designated as a provider of a very large online platform […] where […] the average number of monthly active recipients of the service in the Union, calculated as an average over the period of the past six months, is equal to or higher than 45 million."
— Article 33(1), Regulation (EU) 2022/2065 (Digital Services Act)
Why It Matters
VLOPs play a central role in how political advertising reaches voters. Because of their massive user base and influence, they can amplify political messages—including potentially misleading or manipulative content—at unprecedented scale. Under the DSA, VLOPs must identify and mitigate systemic risks to electoral processes, civic discourse, and public security.
For political advertisers, sponsors, and publishers, VLOPs are often the primary channel for reaching audiences. The stricter transparency and accountability rules mean VLOPs must maintain detailed ad repositories, enable scrutiny by researchers and civil society, and respond quickly to risks during elections. These obligations directly affect how political campaigns can target voters and how the public can verify who is behind political ads.
VLOPs designated under the DSA must also comply with the Transparency and Targeting of Political Advertising Regulation (TTPA), ensuring that political ads are clearly labeled, that sponsors are disclosed, and that targeting practices are transparent and lawful.
Key Points
- User threshold: A platform is designated as a VLOP when it reaches 45 million monthly active users in the EU (roughly 10% of the EU population).
- Designation by the European Commission: The Commission officially designates VLOPs based on user data provided by the platforms themselves.
- Systemic risk obligations: VLOPs must conduct annual risk assessments covering illegal content, fundamental rights, civic discourse, electoral processes, gender-based violence, mental health, and protection of minors.
- Mandatory independent audits: VLOPs must undergo yearly audits to verify compliance with DSA obligations.
- Ad transparency repository: VLOPs must maintain a searchable, public database of all advertisements shown on their platform, including political ads.
- Enhanced accountability: VLOPs face higher fines (up to 6% of global turnover) and direct supervision by the European Commission.
Very Large Online Platform (VLOP) vs. Online Platform
While every VLOP is an online platform, not every online platform is a VLOP. The distinction lies in scale and obligations.
An online platform is any hosting service that stores and publicly disseminates information at a user's request—such as social networks, marketplaces, app stores, or content-sharing sites. Online platforms face baseline DSA obligations like notice-and-action mechanisms, transparency reporting, and advertising disclosure.
A VLOP is an online platform that crosses the 45 million monthly active user threshold in the EU. This designation triggers additional, stricter obligations: systemic risk assessments, independent audits, crisis response mechanisms, researcher data access, and ad repositories. VLOPs are supervised directly by the European Commission, not national authorities.
For political advertising, this means VLOPs must not only label and disclose ads (like all platforms) but also proactively assess and mitigate risks to elections, maintain comprehensive ad archives, and allow vetted researchers to study political ad targeting.