Commission fines X €120 million under DSA (5 December 2025) — first non-compliance decision
Analysis
By UA Ledger staff — 1 min read

On 5 December 2025 the Commission fined X €120 million for DSA breaches on blue-checkmark design, advertising-repository transparency and researcher access to public data — the first DSA non-compliance decision.
On 5 December 2025, the European Commission fined X €120 million for breaching transparency obligations under the Digital Services Act. The press page states this is the first non-compliance decision under the DSA. The VLOP supervision list (updated 31 August 2026) records the same fine date under X Internet Unlimited Company’s enforcement timeline.
Breaches named by the Commission
- Deceptive design of the blue checkmark — paid “verified” status without meaningful identity verification, contrary to DSA rules against deceptive design.
- Advertising repository — fails transparency and accessibility requirements; design barriers and missing critical fields (including ad content/topic and paying legal entity) hinder scrutiny of scams and influence operations.
- Researcher access to public data — terms and processes impose unnecessary barriers, including scraping prohibitions for eligible researchers.
The fine reflects nature, gravity for EU users, and duration of the infringements.
UA reading
This is a precedent on VLOP ad-library quality and researcher access. It does not itself change TikTok or Meta repository rules (those are separate decisions). Game advertisers using X should expect continued pressure on ad-transparency tooling quality across VLOPs.
| Field | Evidence |
|---|---|
| Decision date | 2025-12-05 |
| Fine | €120 million |
| First DSA non-compliance decision | Yes (Commission press) |
| Ad-repository breach | Confirmed |
| Researcher-access breach | Confirmed |
Research checked 20 September 2026. Local draft; human editorial review pending.
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