Very Large Online Search Engine (VLOSE)
A Very Large Online Search Engine (VLOSE) is an online search engine that has an average of 45 million or more monthly active users in the European Union. This threshold represents approximately 10% of the EU's population. VLOSEs face stricter transparency and content moderation obligations under the Digital Services Act to address their significant societal impact and potential systemic risks.
Legal Basis
"Very large online search engine means an online search engine with an average of 45 million or more monthly active recipients of the service in the Union, calculated as an average over the period of six months."
— Article 3(j), Regulation (EU) 2022/2065 (Digital Services Act)
Why It Matters
VLOSEs play a crucial role in how people access information and form opinions, making them particularly important during elections and political campaigns. The 45-million-user threshold triggers additional obligations under the Digital Services Act, including requirements to assess and mitigate systemic risks, conduct independent audits, and provide greater transparency about their algorithms and content moderation practices.
For political advertisers and platforms, VLOSE designation means stricter rules around political advertising transparency under the TTPA Regulation. VLOSEs must ensure political advertisements are clearly labeled, provide transparency notices about sponsors, and restrict the use of targeting techniques based on personal data. They must also establish reporting channels for users to flag missing or incorrect labels on political ads.
These obligations help protect electoral integrity by making it harder for foreign actors to interfere in EU elections and easier for voters to understand who is trying to influence them and why. VLOSEs must maintain higher standards of content moderation and work more closely with EU authorities during election periods.
Key Points
- Threshold: 45 million monthly active users in the EU triggers VLOSE designation by the European Commission
- Systemic risk obligations: Must identify and mitigate risks to electoral processes, fundamental rights, public health, and civic discourse
- Political advertising rules: Must implement enhanced transparency measures for political ads, including clear labeling and sponsor disclosure
- Targeting restrictions: Limited use of personal data for political ad targeting, with prohibitions on sensitive data categories
- Audit requirements: Must undergo annual independent audits of compliance with DSA obligations
- Crisis response: Subject to special crisis protocols during elections or public emergencies requiring rapid action
VLOSE vs. Very Large Online Platform (VLOP)
While both VLOSEs and VLOPs share the same 45-million-user threshold and many similar obligations under the Digital Services Act, they serve different functions. A VLOSE helps users search for and discover information across the web, while a VLOP stores and disseminates content to the public (such as social networks or marketplaces).
The key distinction lies in their primary function: VLOSEs index and rank information from across the internet, while VLOPs host and distribute user-generated content. Both must comply with enhanced transparency requirements for political advertising under the TTPA Regulation, but the specific risks they pose differ—VLOSEs primarily influence what information users find, while VLOPs shape how content spreads and reaches audiences.
Some services may be designated as both if they offer both search and platform functionalities, requiring compliance with all applicable obligations.
Related Terms
- Very Large Online Platform (VLOP)
- Digital Services Act (DSA)
- Political advertising
- Targeting techniques
- Ad-delivery techniques
- Systemic risk assessment
- Online platform
- Transparency notice
- Political advertising services provider
- Digital Services Coordinator