DSA: Guidance on the requirement to publish user numbers

Since the adoption and entry into force of the DSA, a number of providers of intermediary services have contacted the Commission services in preparation for the entry into application of the DSA.

In this context, given the novel nature of the obligations laid down by the DSA, practical questions have been raised on the provisions of the DSA concerning the obligation to publish information on the average monthly active recipients of the service in the Union, which is also relevant for the designation of VLOPs and VLOSEs. This concerns in particular Article 24(2) and recital 77 DSA, as well as Article 3(m), (p) and (q) DSA and Article 33 DSA.

Against this background, this document provides answers to a number of questions that the Commission services have received from providers of intermediary services in light of the deadline of 17 February 2023, laid down in Article 24(2) DSA, for the first publication of information on the number of average monthly active recipients of the service.

The guidance provided in this document is compiled on the basis of the information available to the Commission services on the date of its publication.

This guidance may be subject to review based on practical experience acquired in the months to come.

The guidance is available in all EU official languages.