Wikipedia
The only non-profit designated service, and a recurring reference point in arguments about proportionality.
- Tier
- VLOP — very large online platform
- Provider
- Wikimedia Foundation Inc
- Sector
- Knowledge
- Designated
- 25 April 2023
- Obligations from
- 25 August 2023
- EU users at designation
- 151.1 million
- Formal proceedings
- None to date
- Court challenges
- None
Designated 25 April 2023 on 151.1 million average monthly active recipients in the Union.
Wikipedia is the only designated service run by a non-profit, and the Wikimedia Foundation has argued publicly that duties calibrated for advertising-funded platforms sit awkwardly on a volunteer-moderated encyclopaedia — the Article 39 advertising repository, for instance, is empty by construction.
Where Wikipedia 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.
A regime calibrated for advertising-funded platforms, applied to a non-profit
The asymmetric obligations were written with commercial, advertising-funded, centrally-moderated platforms in mind. Applying them to a volunteer-moderated non-profit produces some duties that are demanding and others that are close to vacuous.
The Article 39 advertising repository is empty by construction where a service carries no advertising. Article 38’s non-profiling requirement has little to bite on where there is no personalised ranking. But Articles 34 and 35 still require a full systemic risk assessment and mitigation programme, and Article 37 still requires an audit paid for out of donations.
The proportionality argument this raises — that a designation threshold based purely on reach captures services whose risk profile and resources look nothing like the rest of the tier — is the strongest structural criticism of Article 33 as drafted.
- Near-empty
- Article 39 advertising repository, where the service carries no advertising.
- Full force
- Articles 34, 35 and 37 — risk assessment, mitigation and independent audit.
Wikipedia 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 Wikipedia 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
Designated on the same day (25 April 2023): Google Search, Bing, YouTube, Google Play, Google Maps, Facebook, Instagram, Amazon Store, TikTok, Pinterest, App Store, X, AliExpress, Snapchat, Zalando, Google Shopping, LinkedIn, Booking.com.