average monthly active recipients of their service in the Union, calculated as an average over the period of the past six months
And the definition of active recipient:
(p) ‘active recipient of an online platform’ means a recipient of the service that has engaged with an online platform by either requesting the online platform to host information or being exposed to information hosted by the online platform and disseminated through its online interface;
So you just need 45 million EU citizens looking at a platform to qualify as a VLOP. Amazon probably qualifies, but it would be easy for them to prove they were unfairly discriminated against as well.
Thank you! Here’s the actual PDF doc of their clarifications and here’s the original DSA
The specific language for number of users is:
And the definition of active recipient:
So you just need 45 million EU citizens looking at a platform to qualify as a VLOP. Amazon probably qualifies, but it would be easy for them to prove they were unfairly discriminated against as well.