# VLOP/VLSE Framework — legal context bundle > Curated from overview.legal on 2026-08-22. Canonical page: https://overview.legal/topics/vlop-vlse-regulatory-framework-overview > Sources are cited per item. Verify against the official texts before relying on them. The content title specifically focuses on 'Very large online platforms and very large online search engines' as a distinct regulatory category under the DSA. A dedicated topic covering the comprehensive regulatory framework, definitions, and comparative analysis of these two service categories would provide better organization and clarity than distributing this information across multiple existing topics. ## Overview ## Legal Framework The DSA establishes a tiered regulatory architecture, with Very Large Online Platforms (VLOPs) and Very Large Online Search Engines (VLSEs) subject to the most stringent obligations. Article 33 DSA sets the designation mechanism: the Commission designates a platform or search engine as "very large" when it exceeds 45 million average monthly active recipients in the Union, calculated as an average over the preceding six months. Once designated under Article 33(4), the provider must comply with enhanced obligations including systemic risk assessments (Article 34), mitigation measures (Article 35), independent audits (Article 37), recommender system transparency (Article 38), data access for researchers (Article 40), and crisis response cooperation (Article 36). Article 92 DSA governs the temporal application of these obligations. Designated providers must comply from four months after the notification under Article 33(6), or by 17 February 2024—whichever is earlier. This staggered entry into force ensures that newly designated services have a defined adaptation window while maintaining the overall regulatory timeline. Article 65 DSA addresses enforcement specifically for VLOPs and VLSEs. It grants the Commission exclusive competence to supervise compliance with the obligations applicable to these providers, including the power to conduct inspections, request information, and impose fines up to 6% of global annual turnover. This centralizes enforcement at the EU level rather than distributing it across national Digital Services Coordinators. ## Key Developments The Commission designated the first wave of VLOPs and VLSEs in 2023, capturing major search engines, social media platforms, and marketplace services. Subsequent designations have expanded the cohort, with the 45-million-user threshold proving the operative trigger. The Commission's preliminary proceedings against certain designated platforms under Article 66 DSA have begun shaping expectations around risk assessment depth, mitigation effectiveness, and transparency report granularity. Enforcement signals indicate particular scrutiny of recommender system compliance and the adequacy of researcher data access mechanisms. ## Practical Guidance - **Monitor user metrics continuously**: Track average monthly active recipients in the EU using the methodology in Article 33(3) DSA. Publish figures at least every six months and prepare for designation once the 45-million threshold is approached or crossed. - **Prepare a compliance readiness roadmap before designation**: Article 92 DSA allows only four months post-notification. Pre-designation preparation for systemic risk assessments, audit infrastructure, and crisis response protocols is essential to meet the deadline. - **Establish a Commission liaison function**: Because Article 65 DSA centralizes enforcement at the Commission level, maintain direct regulatory communication channels and internal processes for responding to information requests and inspections. - **Implement auditable mitigation frameworks**: Article 35 DSA requires mitigation measures proportionate to identified systemic risks. Document decision-making, measure effectiveness, and maintain evidence trails for the independent audit required under Article 37. - **Build researcher access infrastructure proactively**: Article 40 DSA data access obligations require technical and legal readiness. Establish vetting procedures, data schemas, and access controls before designation rather than retrofitting them under enforcement pressure. ## Legislation (full text of key provisions) ### Enforcement of obligations of providers of very large online platforms and of very large online search engines *Source: DSA, dsa-art-65-en, 2022-10-19 — https://overview.legal/posts/95087* ### Anticipated application to providers of very large online platforms and of very large online search engines *Source: DSA, dsa-art-92-en, 2022-10-19 — https://overview.legal/posts/95389* This Regulation shall apply to providers of very large online platforms and of very large online search engines designated pursuant to Article 33(4) from four months after the notification to the provider concerned referred to in Article 33(6) where that date is earlier than 17 February 2024. ### Very large online platforms and very large online search engines *Source: DSA, dsa-art-33-en, 2022-10-19 — https://overview.legal/posts/94528* ### Recommender systems *Source: DSA, dsa-art-38-en, 2022-10-19 — https://overview.legal/posts/94670* In addition to the requirements set out in Article 27, providers of very large online platforms and of very large online search engines that use recommender systems shall provide at least one option for each of their recommender systems which is not based on profiling as defined in Article 4, point (4), of Regulation (EU) 2016/679. ### Recital 83 — very large online platforms health risks *Source: DSA, dsa-rec-83-en, 2022-10-19 — https://overview.legal/posts/95563* A fourth category of risks stems from similar concerns relating to the design, functioning or use, including through manipulation, of very large online platforms and of very large online search engines with an actual or foreseeable negative effect on the protection of public health, minors and serious negative consequences to a person's physical and mental well-being, or on gender-based violence. Such risks may also stem from coordinated disinformation campaigns related to public health, or from online interface design that may stimulate behavioural addictions of recipients of the service. ### Recital 99 — independent compliance function for very large online platforms *Source: DSA, dsa-rec-99-en, 2022-10-19 — https://overview.legal/posts/95595* Given the complexity of the functioning of the systems deployed and the systemic risks they present to society, providers of very large online platforms and of very large online search engines should establish a compliance function, which should be independent from the operational functions of those providers. The head of the compliance function should report directly to the management of those providers, including for concerns of non-compliance with this Regulation. The compliance officers that are part of the compliance function should have the necessary qualifications, knowledge, experience and ability to operationalise measures and monitor the compliance with this Regulation within the organisation of the providers of very large online platform or of very large online search engine. Providers of very large online platforms and of very large online search engines should ensure that the compliance function is involved, properly and in a timely manner, in all issues which relate to this Regulation including in the risk assessment and mitigation strategy and specific measures, as well as assessing compliance, where applicable, with commitments made by those providers under the codes of conduct and crisis protocols they subscribe to. ### Recital 92 — independent compliance audits for very large online platforms *Source: DSA, dsa-rec-92-en, 2022-10-19 — https://overview.legal/posts/95581* Given the need to ensure verification by independent experts, providers of very large online platforms and of very large online search engines should be accountable, through independent auditing, for their compliance with the obligations laid down by this Regulation and, where relevant, any complementary commitments undertaken pursuant to codes of conduct and crises protocols. In order to ensure that audits are carried out in an effective, efficient and timely manner, providers of very large online platforms and of very large online search engines should provide the necessary cooperation and assistance to the organisations carrying out the audits, including by giving the auditor access to all relevant data and premises necessary to perform the audit properly, including, where appropriate, to data related to algorithmic systems, and by answering oral or written questions. Auditors should also be able to make use of other sources of objective information, including studies by vetted researchers. Providers of very large online platforms and of very large online search engines should not undermine the performance of the audit. Audits should be performed according to best industry practices and high professional ethics and objectivity, with due regard, as appropriate, to auditing standards and codes of practice. Auditors should guarantee the confidentiality, security and integrity of the information, such as trade secrets, that they obtain when performing their tasks. This guarantee should not be a means to circumvent the applicability of audit obligations in this Regulation. Auditors should have the necessary expertise in the area of risk management and technical competence to audit algorithms. They should be independent, in order to be able to perform their tasks in an adequate and trustworthy manner. They should comply with core independence requirements for prohibited non-auditing services, firm rotation and non-contingent fees. If their independence and technical competence is not beyond doubt, they should resign or abstain from the audit engagement. ### Recital 95 — very large online platforms advertisement repositories *Source: DSA, dsa-rec-95-en, 2022-10-19 — https://overview.legal/posts/95587* Advertising systems used by very large online platforms and very large online search engines pose particular risks and require further public and regulatory supervision on account of their scale and ability to target and reach recipients of the service based on their behaviour within and outside that platform’s or search engine's online interface. Very large online platforms or very large online search engines should ensure public access to repositories of advertisements presented on their online interfaces to facilitate supervision and research into emerging risks brought about by the distribution of advertising online, for example in relation to illegal advertisements or manipulative techniques and disinformation with a real and foreseeable negative impact on public health, public security, civil discourse, political participation and equality. Repositories should include the content of advertisements, including the name of the product, service or brand and the subject matter of the advertisement, and related data on the advertiser, and, if different, the natural or legal person who paid for the advertisement, and the delivery of the advertisement, in particular where targeted advertising is concerned. This information should include both information about targeting criteria and delivery criteria, in particular when advertisements are delivered to persons in vulnerable situations, such as minors. ### Recital 75 — very large online platforms specific obligations *Source: DSA, dsa-rec-75-en, 2022-10-19 — https://overview.legal/posts/95547* Given the importance of very large online platforms, due to their reach, in particular as expressed in the number of recipients of the service, in facilitating public debate, economic transactions and the dissemination to the public of information, opinions and ideas and in influencing how recipients obtain and communicate information online, it is necessary to impose specific obligations on the providers of those platforms, in addition to the obligations applicable to all online platforms. Due to their critical role in locating and making information retrievable online, it is also necessary to impose those obligations, to the extent they are applicable, on the providers of very large online search engines. Those additional obligations on providers of very large online platforms and of very large online search engines are necessary to address those public policy concerns, there being no alternative and less restrictive measures that would effectively achieve the same result. ### Recital 137 — Union supervision of very large online platforms *Source: DSA, dsa-rec-137-en, 2022-10-19 — https://overview.legal/posts/95671* Given the importance of very large online platforms or very large online search engines, in view of their reach and impact, their failure to comply with the specific obligations applicable to them may affect a substantial number of recipients of the services across different Member States and may cause large societal harms, while such failures may also be particularly complex to identify and address. For this reason the Commission, in cooperation with the Digital Services Coordinators and the Board, should develop the Union expertise and capabilities as regards the supervision of very large online platforms or very large online search engines. The Commission should therefore be able to coordinate and rely on the expertise and resources of such authorities, for example by analysing, on a permanent or temporary basis, specific trends or issues emerging with regard to one or more very large online platforms or very large online search engines. Member States should cooperate with the Commission in developing such capabilities, including through secondment of personnel where appropriate, and contributing to the creation of a common Union supervisory capacity. In order to develop the Union expertise and capabilities, the Commission may also draw on the expertise and capabilities of the Observatory on the Online Platform Economy as set up in Commission Decision of 26 April 2018 on setting up the group of experts for the Observatory on the Online Platform Economy, relevant expert bodies, as well as centres of excellence. The Commission may invite experts with specific expertise, including in particular vetted researchers, representatives of Union agencies and bodies, industry representatives, associations representing users or civil society, international organisations, experts from the private sector, as well as other stakeholders. ## Related topics - **Competent Authorities Designation and Powers under DSA** — https://overview.legal/topics/dsa-competent-authorities-designation The content is titled 'Competences' from the DSA and discusses the allocation and scope of authority powers under the Digital Services Act. 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A dedicated topic for DSA scope is needed to distinguish it from AI Act scope provisions and --- Generated by overview.legal · https://overview.legal/topics/vlop-vlse-regulatory-framework-overview · 2026-08-22