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The European Commission fined X €120 million on 5 December 2025 for three Digital Services Act transparency failures: a paid blue checkmark design it found deceptive, an inadequate advertising repository, and barriers to researchers’ access to public data. The case did not make paid subscriptions or paid badges unlawful in themselves; it concerned how X’s design communicated verification and how the platform met separate transparency duties.
What did the Commission decide?
The Commission’s decision found X, formerly Twitter, in breach of DSA obligations relating to the blue checkmark interface, its advertising repository and researchers’ access to data. It imposed a €120 million fine for those failures. The Commission did not announce separate fine amounts for each issue in the information available here.
The case moved through several procedural stages. The 2024 findings were preliminary; the €120 million sanction came with the Commission’s final decision in December 2025. In 2026, the Commission accepted an action plan from X addressing transparency and researcher-access obligations, showing that remediation remained under follow-up. Acceptance of a plan is not, by itself, evidence that the Commission had declared every issue resolved.
How did the case progress?
| Date | Stage | What it established |
|---|---|---|
| 25 April 2023 | X designated a Very Large Online Platform (VLOP) | The designation followed X’s report of 112 million monthly active users in the EU, according to the European Commission’s 2023 notice. |
| 18 December 2023 | Formal proceedings opened | The Commission identified concerns involving subscription checkmarks, advertising transparency and researchers’ access to data. These were suspected breaches at this stage, not a final decision. |
| 12 July 2024 | Preliminary findings issued | The Commission said it preliminarily considered X in breach in areas associated with Articles 25, 39 and 40(12). The potential maximum fine cited at this stage was up to 6% of worldwide annual turnover. |
| 5 December 2025 | Decision and fine | The Commission found the three transparency failures and imposed a €120 million fine. |
| 2026 | Action plan accepted | The Commission accepted an X plan addressing transparency and researcher-access obligations; follow-up was still underway. |
Why did the blue checkmark breach the DSA?
The Commission treated the checkmark as a user-interface transparency issue under Article 25, which addresses deceptive design. Its concern was that a badge obtained through a subscription could look like a verification mark without meaningful identity verification. Because users may read a checkmark as evidence that an account’s identity has been checked, the interface could mislead them about who was behind an account and affect their ability to make informed decisions.
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The Commission’s preliminary findings said the verified-account interface did not correspond to industry practice and could deceive users. The legal issue was how the feature conveyed authenticity—not whether people may pay for a subscription or receive a badge. The decision therefore should not be read as a blanket ban on paid subscriptions or paid account labels under the DSA.
What were the other two violations?
| Obligation | What the DSA requires | What the Commission found about X |
|---|---|---|
| Article 39: advertising repository | VLOPs must maintain an ad repository that is searchable, reliable and accurate, supporting scrutiny of advertising on the service. | The Commission found X’s repository insufficiently transparent. |
| Article 40(12): researcher access | VLOPs must provide effective access to platform data so independent researchers can study systemic risks. | The Commission found that barriers imposed by X impaired researchers’ access to public data. |
These requirements concern platform infrastructure as well as what users see in the app. The ad repository is intended to make advertising activity inspectable; researcher access supports independent study of risks associated with a very large platform.
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Why was X subject to these stricter rules?
The DSA imposes enhanced duties on services designated as Very Large Online Platforms, including obligations concerning systemic risks and transparency. The Commission designated X a VLOP on 25 April 2023 after the company reported 112 million monthly active users in the EU. That reported EU audience was the basis cited for the designation; it should not be confused with a current user count.
When the Commission opened proceedings in December 2023, Executive Vice-President Margrethe Vestager described the rationale for enhanced requirements: “The higher the risk large platforms pose to our society, the more specific the requirements of the Digital Services Act are.”
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What does the €120 million fine mean?
The €120 million is the fine imposed in the Commission’s 5 December 2025 decision. It is not the same as the up-to-6%-of-worldwide-annual-turnover maximum mentioned during the July 2024 preliminary stage. That earlier figure described the potential ceiling for a fine under the DSA, not the amount X ultimately received.
The Commission’s stated sanction covers the findings in this case; the available decision summary does not allocate the fine among the blue-check design, ad repository and researcher-access failures. It would therefore be misleading to assign a specific share of the €120 million to any one of them.
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