X
The first service fined under the DSA — €120 million in December 2025 — and the subject of a second proceeding into Grok.
- Tier
- VLOP — very large online platform
- Provider
- X Internet Unlimited Company
- Sector
- Social
- Designated
- 25 April 2023
- Obligations from
- 25 August 2023
- EU users at designation
- 115.1 million
- Formal proceedings
- 2
- Court challenges
- None
Designated 25 April 2023 on 115.1 million average monthly active recipients in the Union.
The Commission opened proceedings on 18 December 2023 and on 5 December 2025 issued the DSA’s first non-compliance decision, fining X €120 million on three counts: a deceptive paid verification checkmark, an advertising repository that was neither complete nor reliably accessible, and terms and access procedures that obstructed researchers.
A second proceeding opened on 26 January 2026 into risks arising from the deployment of Grok, extending the original case to X’s recommender systems including the planned switch to a Grok-based recommender.
Where X 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.
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.
Formal proceedings
Deceptive design, advertising transparency and researcher data access
Partially resolvedOpened 18 December 2023
€120 million fine, 5 December 2025 see all fines
- ·Notice-and-action mechanisms and systemic risk management
- ·Deceptive design of the paid verification checkmark
- ·Advertising repository completeness and accessibility (Article 39)
- ·Researcher access to public data (Article 40)
Risks arising from the deployment of Grok, and recommender systems
OpenOpened 26 January 2026
- ·Systemic risks from the deployment of Grok on the platform (Articles 34–35)
- ·Recommender systems, including a planned switch to a Grok-based recommender (Article 38)
X timeline
- 25 April 2023 Designated a VLOP by Commission decision.
- 25 August 2023 Articles 33 to 43 begin to apply, four months after notification.
- 18 December 2023 Formal proceedings opened.
- 5 December 2025 Commission fines X €120 million on three counts: the deceptive paid checkmark, an incomplete and unreliably accessible advertising repository, and terms and procedures that obstructed researchers. X must submit remedial plans within 60 days on the checkmark and 90 days on advertising and data access, or face periodic penalty payments.
- 26 January 2026 Proceedings opened into risks from Grok’s deployment, extending the existing case to X’s recommender systems.
What X 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, Snapchat, Reddit, LinkedIn.
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, AliExpress, Snapchat, Zalando, Google Shopping, LinkedIn, Booking.com.