EU to Label WhatsApp Open Channels as DSA VLOP

The European Commission is reportedly set to designate WhatsApp’s open channels as a Very Large Online Platform under the Digital Services Act. Bloomberg indicates Meta has been informed, though no formal Commission announcement has been made. The designation follows WhatsApp’s reported average of about 46.8 million EU users in the second half of 2024, exceeding the DSA’s 45 million monthly user threshold.

VLOP status triggers enhanced obligations on risk management, content moderation processes, transparency, and data access for vetted researchers. WhatsApp’s open channels will be required to undergo annual independent audits and implement traceable, transparent advertising practices. These systemic risk assessments must cover areas such as the dissemination of illegal content and the potential impact on fundamental rights.

Importantly, the designation applies to open channels only and does not affect individual private messaging, which remains outside the scope of the VLOP framework. The separation reflects the DSA’s function-based approach, tethering obligations to public-facing service features where platform reach and amplification pose systemic risks.

WhatsApp’s inclusion follows Meta’s Instagram and Facebook and aligns with existing VLOP designations applied to Amazon, Google, and ByteDance. For compliance teams, immediate priorities include mapping DSA Article 34–39 risk obligations to the open channels feature, preparing audit-readiness documentation, and ensuring ad transparency tools meet Commission guidance.