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EU DSA VLOP designation upheld for Zalando: General Court endorses broad user counting for hybrid marketplaces and mixed‑content platforms

Published on: 11 December 2025

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Zalando v Commission, Case T-348/23, ECLI:EU:T:2025:821

Background: what is a VLOP and why does it matter?

The EU DSA, introduced by the Commission to prevent unlawful and harmful behaviour online and to curb the spread of disinformation, created new categories for online intermediary service providers. All online platforms must calculate and disclose their EU monthly active user figures, and the VLOP label is reserved for services with at least 45 million such users. VLOPs face the most stringent obligations under the DSA, including duties concerning enhanced transparency, risk assessment, data sharing with authorities, and more robust action against illegal content and products. Read more about this in our previous blogs here and here.

The Zalando case: challenging the VLOP status

In April 2023, Zalando was included in the first cohort of platforms designated as VLOPs by the Commission, with the Commission stating that the platform had more than 83 million average monthly active EU users...

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