Twitter meets key hurdle for EU regulation

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There has been some confusion whether Twitter has more than 45m active users in the European Union — a key hurdle for designation as a Very Large Online Platform under the Digital Services Act (Art. 33(1)), and potentially a gatekeeper under the Digital Markets Act (Art. 3(2)(b)).

I’ve finally found comprehensive country-level data from Kepios, which shows that in July 2022 Twitter reported 61.9m users reachable by advertisers in the 27 member states (I excluded separated-out regions such as Réunion and Saint Martin/Siint Marten):

I’ve contributed this data to a commons maintained by DataWrapper, so feel free to build on/update it!

UPDATE 4/1/23: Thanks to Chris Marsden for pointing out Twitter’s July 2022 figures on “monetisable Daily Active Users” are substantially lower than Kepios’. I’m sceptical this Twitter-specific mDAU measure is analogous to the DSA’s “average monthly active recipients” — which might even be higher than the Kepios figures, since it includes “all the recipients actually engaging with the service at least once in a given period of time, by being exposed to information disseminated on the online interface of the online platform, such as viewing it or listening to it” (recital 77). I’ve seen arguments this would include (for example) viewers of embedded tweets in online news media. Looks like there could be a big battle between Twitter (which must publish its own figure by 17 February 2023 – Article 24(2)) and the European Commission (which I hope is already working on a delegated act setting out its counting methodology – Article 33(3)).