Last updated: Nov 15th, 2025
Regulatory Context
The Digital Services Act (“DSA”) officially became operational across the European Union (“EU”) on November 16, 2022.
Pursuant to the mandates set forth in Article 24 (2) of the DSA, digital hosting platforms are obligated to disclose metrics regarding their average semi-annual active service recipients within the EU territory at minimum intervals of six months. These disclosures serve to identify whether an interactive portal satisfies the criteria for a “Very Large Online Platform” (“VLOP”). Under the DSA framework, a VLOP status is triggered when a platform sustains a minimum threshold of 45 million monthly active consumers inside the EU. Entities designated as VLOPs are legally bound by heightened administrative and compliance regulations under the DSA.
Platform Status Evaluation
Phub hereby verifies that its average volume of monthly active service consumers within the EU boundaries during the evaluation window spanning February 1, 2024, through July 31, 2024, did not cross the 45 million user benchmark. Consequently, Phub continues to rank safely below the volume requirement necessary for a VLOP classification. This statistical projection was compiled in strict conformity with the applicable clauses of the DSA alongside the official interpretative Framework distributed by the European Commission on February 1, 2023.
Moving forward, our compliance teams will persistently audit the rolling volume of average monthly active digital marketplace consumers within the EU zone and will broadcast renewed metrics in strict adherence to the timelines enforced by Article 24 (2).