Emerging VLOPs

As platforms approach Very Large Online Platform (VLOP) thresholds, the window to prepare is narrowing rapidly. Once designated, organisations have just four months to comply with significantly expanded and complex regulatory requirements

The challenge is not just compliance; it is demonstrating compliance under real-time regulatory scrutiny.

Emerging VLOPs: Minimum viable readiness for DSA compliance

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Why this matters now

Regulatory expectations have shifted from policy-based compliance to evidence-based execution.

The European Commission has already issued 64 Requests for Information across major platforms
Formal proceedings have been opened against 11 platforms
Non-compliance can result in fines of up to 6% of global annual turnover
Organisations are now expected to demonstrate that their controls, governance and risk frameworks are operating effectively, not just designed.

What “minimum viable readiness” looks like

Build a minimum viable regulatory framework early, then refine and scale.

In practice, this means:

A defensible operating model that can withstand regulatory scrutiny
Clear accountability across compliance, risk and leadership
Evidence of effective controls, not just policies
Data-driven risk assessment methodologies
Governance structures that enable regulatory oversight

Key areas to prioritise

Emerging VLOPs should focus on getting the following right:

Systemic Risk Assessments (SRAs) – robust, evidence-based and repeatable
Independent Compliance Function – with clear reporting to the Board
Crisis Response & Readiness – tested and operational
Transparency & Reporting – consistent, accurate and audit-ready
Assurance & Remediation – continuous improvement and oversight
Regulatory Engagement – readiness for direct European Commission supervision

How KPMG can help

Our team has deep technical expertise across all DSA related areas, including:

Readiness & Assurance
Control Design & Documentation
Implementation of key processes
Regulatory Engagement & Reporting

In addition, our DSA services are powered by accelerators to ensure an efficient process.

These include

A DSA Compliance Assessment tool, developed and used for DSA compliance projects at other VLOPs / VLOSEs;
A global better practice DSA Audit criteria framework;
Compliance function framework and operating model
SRA report templates and Assessment Methodology

We also leverage proprietary tools and frameworks to accelerate delivery and ensure a structured, efficient approach.

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Start building your readiness today

Early preparation is critical. Organisations that act now will be better positioned to manage risk, meet regulatory expectations, and scale with confidence.