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What the Commission found
In its 5 December 2025 decision, the European Commission found X in breach of DSA transparency duties and imposed a €120 million fine. The decision covered three distinct issues:
- Paid blue checkmarks: The Commission found the design deceptive because the subscription-linked badge could look like a verification signal without meaningful identity verification.
- Advertising repository: The Commission found X’s ad repository insufficiently transparent.
- Researcher access: The Commission found that barriers imposed by X impaired researchers’ effective access to public platform data.
The blue-check issue fell under Article 25, which addresses deceptive interface design. The advertising repository issue involved Article 39, and researcher access involved Article 40(12). These are separate obligations; the fine was not solely about the badge.
Why the paid checkmark raised a DSA issue
A checkmark can shape how users judge an account. Users may read it as evidence that a platform has verified who controls the account, rather than as a sign that the account holder bought a subscription. The Commission’s concern was that X’s subscription-linked badge could create that impression without meaningful identity verification, affecting users’ ability to make informed decisions.
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The Commission described its concern in December 2023 as suspected deceptive interface design “notably in relation to checkmarks linked to certain subscription products, the so-called Blue checks.” In July 2024, its preliminary findings said the verified-account interface did not correspond to industry practice and could deceive users. The December 2025 decision then found a breach.
This distinction matters: the case does not establish that every paid badge or subscription is unlawful. It concerns the way this particular feature communicated authenticity under the DSA’s rules on interface design.
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The other transparency failures
Advertising repository: Article 39
The DSA requires very large online platforms (VLOPs) to maintain an ad repository that is searchable, reliable and accurate. The Commission found X’s implementation insufficiently transparent. Ad repositories help people and researchers examine platform advertising; the finding was about whether X’s repository met the required standard.
Researcher access: Article 40(12)
The DSA also requires VLOPs to provide effective access to platform data so independent researchers can study systemic risks. The Commission found that X’s barriers impaired that access. The decision therefore addressed more than what ordinary users saw in the interface: it also covered the information and tools needed to scrutinize the platform.
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- Are you really yourself? Better go blue check if there is a blue checkmark verification badge. For fans of social media, blue check marks, internet geeks and digital celebrities who really want to be sure about themselves.
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Why X faced enhanced DSA obligations
The Commission designated X a VLOP, a category subject to enhanced transparency duties and systemic-risk assessments. The designation followed X’s report of 112 million monthly active users in the EU. On 18 December 2023, the Commission opened formal proceedings concerning the checkmarks, the advertising repository and researcher access.
As Margrethe Vestager, then Executive Vice-President for a Europe Fit for the Digital Age, said when the proceedings opened on 18 December 2023: “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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How the case progressed
| Date | Stage | What happened |
|---|---|---|
| 25 April 2023 | VLOP designation | The Commission designated X a VLOP after X reported 112 million monthly active users in the EU. |
| 18 December 2023 | Formal proceedings opened | The Commission identified suspected problems involving the subscription checkmark design, ad-repository transparency and researcher access. |
| 12 July 2024 | Preliminary findings | The Commission said it preliminarily found breaches concerning the checkmark design, advertising transparency and researcher access. It identified Articles 25, 39 and 40(12); potential fines could reach 6% of worldwide annual turnover. |
| 5 December 2025 | Decision and fine | The Commission found breaches in the three areas and imposed a €120 million fine. |
| 2026 | Follow-up | The Commission accepted an X action plan addressing transparency and researcher-access obligations. This shows that remediation was still being followed up; it does not erase the 2025 decision. |
What this means for users and subscribers
The decision is about platform design and transparency, not a general ban on paying for account features. For users, its practical point is to distinguish a subscription signal from an assurance that a platform has verified identity. The Commission’s finding concerns the impression the checkmark could create in X’s interface.
The Commission’s cited notices do not establish one current X Blue price or availability across every EU country. Those details can vary and are not necessary to understand the DSA decision.
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