VLOP threshold: 45m monthly active recipients, not registered users

The DSA defines a very large online platform (VLOP) or search engine as one with at least 45 million average monthly active recipients in the EU. This figure is roughly 10% of the EU population, so you can quickly check: if the platform's EU user base is about one in ten people, it likely crosses the threshold. The key contrast is that the DSA counts 'recipients'—anyone exposed to the platform's content or services, even without an account—not just registered users. For example, a news site that logs visits counts everyone who loads a page, not only those who sign up.

To avoid the common trap, remember that the threshold is based on 'active recipients' averaged over six months, not a single month's peak. A quick elimination trick: if a question mentions 'registered users' or 'subscribers', it's likely a distractor. Another hint: the 45 million figure is fixed in the regulation, but the European Commission updates the list of VLOPs periodically, so the exact number of platforms can change. When comparing with the DMA, note that the DMA uses a different threshold (€7.5bn turnover or 45m users) and focuses on 'core platform services', not just content distribution.

To test yourself, ask: 'Would a platform with 50 million unique monthly visitors but only 10 million registered accounts qualify?' Yes, because the DSA counts recipients, not accounts. The quick memory aid: '45 million = 10% of EU = systemic risk duties kick in.'