Designated on a figure only marginally above the threshold.
- Tier
- VLOP — very large online platform
- Provider
- LinkedIn Ireland Unlimited Company
- Sector
- Social
- Designated
- 25 April 2023
- Obligations from
- 25 August 2023
- EU users at designation
- 45.2 million logged-in; 132.5 million site visits
- Formal proceedings
- None to date
- Court challenges
- None
Designated 25 April 2023 on 45.2 million logged-in average monthly active recipients in the Union, against 132.5 million site visits.
The gap between those two figures is the clearest published illustration of what “active recipient” means under Article 3(p): unique users actually engaging with the service, not raw traffic.
Where LinkedIn sits in the tier
That margin is thin. A service this close to the threshold is one reporting period away from the question Article 33(5) exists to answer — designation is withdrawn where user numbers fall durably below 45 million, as they did for Stripchat in May 2025.
Amplification, minors, and civic discourse
For a feed-based platform the Article 34 assessment lands squarely on the recommender system: how ranking and amplification shape what spreads, and whether that design contributes to the dissemination of illegal content or to negative effects on civic discourse and electoral processes.
Article 38 requires at least one feed option not based on profiling, directly accessible from the interface where recommendations appear. Article 27, which applies to all online platforms, separately requires the main parameters of the recommender to be explained in the terms.
Article 28 and the July 2025 minors guidelines add a design layer: default settings for minors’ accounts, age assurance, and features that extend engagement are all in scope, and are the subject of several open proceedings.
- Article 27
- Recommender transparency, applying to all online platforms.
- Article 28
- Protection of minors, including default account settings.
LinkedIn timeline
- 25 April 2023 Designated a VLOP by Commission decision.
- 25 August 2023 Articles 33 to 43 begin to apply, four months after notification.
What LinkedIn has to do
Designation applies the asymmetric obligations in Articles 33 to 43. They are the same for every designated service, read against a platform surface. Terms used on this page are collected in the glossary.
- Article 34 Systemic risk assessment
- Article 35 Mitigation of risks
- Article 37 Independent audit
- Article 38 Recommender systems without profiling
- Article 39 Advertising repository
- Article 40 Data access for the Commission and vetted researchers
- Article 41 Internal compliance function
- Article 42 Transparency reporting
- Article 43 Supervisory fee
Related designations
Other social services in the tier: Facebook, Instagram, Pinterest, X, Snapchat, Reddit.
Designated on the same day (25 April 2023): Google Search, Bing, YouTube, Google Play, Google Maps, Facebook, Instagram, Amazon Store, Wikipedia, TikTok, Pinterest, App Store, X, AliExpress, Snapchat, Zalando, Google Shopping, Booking.com.