XNXX
Designated in July 2024 and named in the joint age-assurance proceeding.
- Tier
- VLOP — very large online platform
- Provider
- NKL Associates s.r.o
- Sector
- Adult
- Designated
- 10 July 2024
- Obligations from
- 10 November 2024
- EU users at designation
- 45 million
- Formal proceedings
- 1
- Court challenges
- None
Designated 10 July 2024 on 45 million average monthly active recipients in the Union.
Named in the Commission’s 27 May 2025 proceeding into the protection of minors on adult platforms.
Where XNXX 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close to the threshold is one reporting period away from the question Article 33(5) exists to answer — designation is withdrawn where user numbers fall durably below 45 million, as they did for Stripchat in May 2025.
Age assurance is the whole of the enforcement question
For adult platforms the binding constraint is Article 28(1): platforms accessible to minors must put in place appropriate and proportionate measures ensuring a high level of privacy, safety and security for them. Read with the Article 34 and 35 duties, that becomes a systemic-risk question about who can reach the service at all.
The Commission’s guidelines of 14 July 2025 closed off the cheapest answer. Self-declared age is not sufficient. Providers are expected to assess whether age verification or age estimation is appropriate, using methods that are accurate, reliable, robust, non-intrusive and non-discriminatory — and the Commission published a prototype EU age verification app, which lets a user present a proof-of-age attestation without handing the platform their identity documents.
The joint proceeding opened on 27 May 2025 against four adult platforms turns precisely on whether self-declaration gates satisfy any of this.
- Article 28
- Protection of minors, as interpreted by the July 2025 guidelines.
- Article 33(5)
- De-designation where user numbers fall durably below the threshold — the one case of this to date was an adult platform.
Formal proceedings
Age assurance and the protection of minors on adult platforms
OpenOpened 27 May 2025
- ·Appropriate and proportionate age assurance (Article 28 and Articles 34–35)
- ·Adequacy of risk assessment on minors’ access
XNXX timeline
- 10 July 2024 Designated a VLOP by Commission decision.
- 10 November 2024 Articles 33 to 43 begin to apply, four months after notification.
- 27 May 2025 Joint proceedings opened against four adult platforms over reliance on self-declaration age gates.
What XNXX 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