Commission designates WhatsApp as VLOP under the Digital Services Act

The European Commission has designated WhatsApp as a Very Large Online Platform (VLOP) under the Digital Services Act (DSA) because its Channels feature has surpassed the EU threshold of 45 million users. That designation applies specifically to WhatsApp Channels, the broadcasting functionality that enables content dissemination to broad audiences; the core private messaging service—text, voice notes, media sharing, and voice/video calls—remains outside the DSA’s scope.

As a VLOP, Meta has four months from the designation date—until mid‑May 2026—to implement the additional DSA obligations that apply to platforms of this scale. These obligations require comprehensive risk assessments and concrete mitigation measures addressing systemic risks such as threats to fundamental rights, misinformation affecting freedom of expression, electoral manipulation, illegal content dissemination, and privacy harms.

The Commission becomes the lead supervisor for WhatsApp’s compliance with the VLOP regime, coordinating its oversight with Ireland’s Digital Services Coordinator, Coimisiún na Meán. Supervision will focus on whether Meta’s technical and organisational measures meet DSA standards for transparency, risk management, independent audits, and reporting duties specific to very large platforms.

Practitioners should note the practical implications: Meta must prepare documented systemic risk analyses, prevention and mitigation strategies, transparency reporting and external audits, and mechanisms for redress and user protection targeted at the Channels service. Legal teams advising platforms or affected stakeholders will need to align contractual, product and compliance workstreams with the DSA timeline and reporting expectations.