Lead Forensics

DSA & You: How do you calculate average monthly active users?

The first deadline of the Digital Services Act (DSA) is approaching fast, all online platforms and search engines have only one more month to publish their Monthly Active User (MAU) numbers.

Getting this number right and keeping it updated is key: The MAU will be used by the Commission to determine which services qualify as very large online platforms (VLOPs) or very large online search engines (VLOSE). If this number surpasses the threshold of 45 million average MAU, your service will be classified as a VLOP or VLOSE which means the DSA´s substantial obligations will be applicable to you as early as from July 2023. 

Will you have to publish your monthly active users and how?

If you are an online platform and you are offering your services in the EU, you will have to publish your monthly active user count on a publicly available section of your website. 

An online platform is a hosting service that makes information available to the public. Offering services in the EUmeans that your service has users in one or more EU countries or that you present your service in a language or a currency generally used in the EU or even simply making your service available in the app stores of EU countries. 

What is a ‘recipient of a service’?

According to the Regulation, ‘recipients of the service’ includes business users, consumers, and all other users. This means that advertisers and traders (anyone selling their product/services online) will also be considered recipients, along with regular users. Crucially, a user does not have to be registered on an online service to count as a ‘recipient’.

Who is an active recipient?

An active recipient is someone who has engaged with an online service. ‘Engaging’ can mean asking a service to host information or viewing information on the online interface of the service. This can be as simple as uploading a photo or seeing a post that someone shared on social media. 

How will active recipients be calculated?

The average MAU will be calculated as an average over a period of 6 months.  

This figure should represent the users engaging with the platform at least once in a given time period. This means that the recipient has interacted with content, provided content, asked to store content, viewed content, or searched for content (in the case of a search engine). They do not have to be a registered user of the platform; as long as they are looking at content on its online interface, they will be counted as an active recipient. It is worth noting that these obligations do not impose additional tracking of individuals online.

Examples for different types of online platforms can include:

  • Gaming platforms: For any gaming platforms or applications, an active recipient can refer to any player or gamer who is interacting with the game or the online platform in general. They do not have to be a registered player or interact with other players to be counted; as long as they can see content shared by other players, they will be counted as an active recipient. 
  • Online marketplace: For online marketplaces, both traders and customers that are on the platforms are active recipients. They do not have to be participating in transactions to be counted, as long as they can see the content shared by other traders and customers on the online interface of the service, they will be counted as an active recipient. 
  • Online search engine: For online search engines, anyone who has submitted a query and received results from the engine is counted as an active recipient. Here, a person will have to submit a ‘search’ and see the information indexed by the search engine to be considered as ‘engaging’ with the service. 

What can be excluded from the calculation?

The DSA clarifies that only unique recipients of the service should be counted. This leads to three important exemptions to keep in mind when counting your MAU:

  • If someone accesses your service through their browser as well as an app, they should only be counted as a single ‘recipient’. 
  • If someone views your service’s content because it is indexed on a search engine, or through embedded linking, they are not counted as a recipient of your service. This means that if you are a video sharing service, and someone reposts a video from your platform on to a different platform, the people that view that embedded link will not be counted as recipients of your platform. Similarly, if your video starts auto-playing on the page of a search engine after someone has submitted a query, they will not be counted as a recipient of your service.
  • Bots or scrapers should be excluded from the calculation as long as they are correctly identified. 

Will the Commission publish a methodology for counting monthly active users? Can I wait until they have?

No, the Commission has not indicated that they will publish any additional guidance on counting monthly active users ahead of the 17th of February 2023 deadline. The calculations will therefore need to be made based on the available information above. 

How can Tremau help?

If you are an online platform, reach out if you need help in calculating your monthly active users ahead of the 17th of February. 

With only 13 months to comply, contact us at info@tremau.com to explore our full list of advisory services to ensure that you will be ready for all the obligations kicking in early 2024.


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