TikTok
The most heavily investigated designated service, with three proceedings opened and the first DSA commitments made binding.
- Tier
- VLOP — very large online platform
- Provider
- TikTok Technology Limited
- Sector
- Video
- Designated
- 25 April 2023
- Obligations from
- 25 August 2023
- EU users at designation
- 135.9 million
- Formal proceedings
- 3
- Court challenges
- T-55/24 and T-58/24
Designated 25 April 2023 on 135.9 million average monthly active recipients in the Union.
Three proceedings have been opened: minors and addictive design (19 February 2024), the TikTok Lite “Task and Reward” programme (22 April 2024, closed), and election integrity following the annulled Romanian presidential election (17 December 2024).
TikTok Lite produced the DSA’s first use of binding commitments — the rewards programme was withdrawn from the Union rather than defended. In December 2025 the Commission accepted and made binding a further set of advertising-transparency commitments under Article 71(1).
Where TikTok sits in the tier
Designation is not a ranking, and the obligations do not scale with size: the smallest designated service carries exactly the same duties in Articles 33 to 43 as the largest.
Recommenders, minors, and the pull of engagement design
Video platforms sit at the sharp end of the recommender provisions. The Article 34 assessment covers how autoplay, ranking and personalised suggestion shape exposure — the “rabbit-hole” framing the Commission has used in its own proceedings is an Articles 34 and 35 argument, not an illegal-content one.
Article 38 requires a non-profiling alternative to the personalised feed, and Article 28 with the July 2025 guidelines governs how the service treats accounts it knows or should know belong to minors.
Video-sharing platforms may also fall under the Audiovisual Media Services Directive at national level, which runs alongside the DSA rather than being displaced by it.
- Article 28
- Protection of minors, including addictive design features.
- Separate regime
- National implementations of the Audiovisual Media Services Directive.
Before the courts
Meta Platforms Ireland and TikTok Technology v Commission — supervisory fees
Meta and TikTok each challenged the Commission’s implementing decisions setting their Article 43 supervisory fees, arguing the methodology produced arbitrary results — most pointedly that keying the cap to group-level net income means a loss-making provider of identical size can owe nothing at all.
The General Court (Extended Composition) annulled the decisions, but on an institutional ground rather than a substantive one. Because the calculation of average monthly active recipients is essential to determining the fee, Article 43(4) required that methodology to be set out in a delegated act. The Commission had used two implementing decisions instead, and that was the wrong instrument.
The Court maintained the effects of the annulled decisions for twelve months, giving the Commission time to re-adopt the methodology in the proper form. The practical result is that the fees stand for now and the machinery gets rebuilt underneath them.
It remains the only successful challenge brought against any part of the DSA’s designated-service regime — and it turned on administrative law, not on whether the tier is justified.
Formal proceedings
Protection of minors, addictive design, advertising and data access
Partially resolvedOpened 19 February 2024
- ·Addictive design and “rabbit-hole” effects (Articles 34–35)
- ·Age verification and the protection of minors
- ·Advertising repository (Article 39)
- ·Researcher data access (Article 40)
TikTok Lite “Task and Reward” programme launched without a prior risk assessment
ClosedOpened 22 April 2024
- ·Launch of a reward feature without a prior Article 34 risk assessment
Election integrity following the annulled Romanian presidential election
OpenOpened 17 December 2024
- ·Risk management of election integrity (Articles 34–35)
- ·Recommender systems and coordinated inauthentic manipulation
- ·Political advertising policies
TikTok timeline
- 25 April 2023 Designated a VLOP by Commission decision.
- 25 August 2023 Articles 33 to 43 begin to apply, four months after notification.
- 19 February 2024 Formal proceedings opened.
- 22 April 2024 Proceedings opened; TikTok suspends the rewards programme in the Union.
- 5 August 2024 Case closed after TikTok commits to permanently withdraw the programme from the Union — the DSA’s first binding commitments.
- 17 December 2024 Formal proceedings opened after Romania annulled its presidential election.
- September 2025 General Court judgment in T-55/24 and T-58/24: annulled.
- 5 December 2025 Commission accepts and makes binding TikTok’s commitments on advertising transparency under Article 71(1).
- 2026 Commission issues preliminary findings that TikTok may have breached transparency obligations. Preliminary findings are not a final decision.
What TikTok 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 video services in the tier: YouTube.
Designated on the same day (25 April 2023): Google Search, Bing, YouTube, Google Play, Google Maps, Facebook, Instagram, Amazon Store, Wikipedia, Pinterest, App Store, X, AliExpress, Snapchat, Zalando, Google Shopping, LinkedIn, Booking.com.