The Digital Services Act introduced direct EU-level enforcement for very large online platforms. For operators below that threshold, the enforcement picture is different and receives less attention.
The DSA separates enforcement by scale. Very large online platforms (VLOPs) and very large online search engines (VLOSEs) — defined by reaching 45 million EU users monthly — are subject to direct enforcement by the European Commission. All other platforms are supervised by national Digital Services Coordinators, newly established bodies with varying capacity across member states.
The Commission has dedicated enforcement resources and political mandate for VLOP cases. For a platform below that threshold, the relevant authority is the DSC of its member state of establishment — and DSC capacity, experience, and priorities vary considerably.
Being below the VLOP threshold does not mean being outside the DSA’s scope. It means being supervised by a different authority, at a different stage of institutional development.
The Commission’s early DSA enforcement focused on recommender systems, advertising transparency, and the handling of illegal content — often timed around visible public events. Enforcement was framed as market signalling, not just individual remedy. This dynamic means the first years of enforcement are concentrated on high-profile situations. Operators at lower public visibility, in specialised sectors, or with B2B structures face a different enforcement landscape.