Hi Matthias, Thanks for flagging this and for breaking it down! The cumulative criteria do indeed create an interesting cascade of requirements.
Under the DSA only Wikipedia has been designated as a VLOP, so all other platforms are out. As for the DMA definition under art. 2(7), it reads: ‘online social networking service’ means a platform that enables end users to connect and communicate with each other, share content and discover other users and content across multiple devices and, in particular, via chats, posts, videos and recommendations. We can make a credible argument that even though Wikipedia allows for some of these things to happen, it is an auxiliary function. Still, asking for a clearer language might be wise. Can you explain a bit more about the login access criteria? Does it say only via login or alos via login? Does the law cover the cases where users login but not when they don't? Let's say I log into Wikipedia and then I need to be over 15, but if I don't, that's fine? I understand the logged in version of some platforms (e.g. YouTube) is different to the not-logged-in version. But what if the service is essentially the same, like Wikipedia. We do have some small differences (e.g. watchlist), but you do get access to all the same content. Dimi На пн, 7.09.2026 г. в 16:00 Matthias Smed Larsen via Publicpolicy < [email protected]> написа: > Hey all > > The Danish government has published a draft bill on an age limit (15 > years) for social media users for comment: > https://hoeringsportalen.dk/Hearing/Details/71440 > > Under the draft § 1, subsection (1)(1)–(3), the bill would apply to > platforms that are covered by the definition in art. 2(7) or (8) in the DMA > (online social networking service or video-sharing platform service), have > been designated as very large online platforms under art. 33 of the DSA > *and* are accessed via login (cumulative criteria). The prohibition is > targeted at the users, not the platforms. > > I know WMF projects are designated as VLOP under the DSA, but do we have > any statement on whether they constitute a social networking service under > art. 2(7) DMA? Note that the draft bill does not appear to require the > platform to have gatekeeper status under the DMA. > > Kind regards, > Matthias > _______________________________________________ > Publicpolicy mailing list -- [email protected] > To unsubscribe send an email to [email protected] >
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