What the EU DSA changes for Telegram impersonation takedowns

Less than many brands hope. As of October 2026, Telegram has not been designated a Very Large Online Platform (VLOP) under the EU's Digital Services Act. It reports significantly fewer than 45 million EU users for the parts of its service the DSA treats as an online platform. The DSA's baseline duties still apply, including a way to report illegal content and an obligation to act on those reports, but the stricter VLOP obligations do not.

Here's what that means in practice for a company reporting fake support accounts on Telegram. For the reporting steps themselves, see how to report a fake support account on Telegram.

Where Telegram stands under the DSA

• Not a VLOP. The DSA's strictest tier applies to platforms with more than 45 million average monthly active users in the EU. Telegram reported 41 million in February 2024 and has since said only that it has significantly fewer than 45 million.

• Supervised in Belgium. Telegram named Belgium as the location of its EU legal representative, so Belgium's regulator, BIPT, oversees its DSA compliance as long as it isn't a VLOP.

• Under scrutiny. Members of the European Parliament have questioned how Telegram counts EU users, and the Commission has said it is monitoring the methodology. Designation could change if its numbers are reassessed.

What baseline DSA duties mean for brands

• A way to report illegal content. Hosting services must offer a mechanism to notify them of illegal content. Impersonation used for fraud, or trademark infringement, can be illegal content under EU or national law.

• A decision and a reason. Platforms must process notices in a timely and diligent way, and online platforms must explain decisions to remove or restrict content.

• Trusted flaggers. Online platforms must prioritize notices from organizations certified as trusted flaggers in an EU country.

What it doesn't change

• There's still no brand or trademark portal on Telegram.

• There's no fixed deadline for acting on a notice.

• VLOP duties, such as systemic risk assessments and independent audits, don't apply to Telegram today.

• The DSA covers the EU. Fakes targeting customers elsewhere fall outside it.

What to do differently

If you have EU customers, frame reports about clearly illegal content, such as fraud or trademark infringement, as notices of illegal content, with the specific law and the exact location of the content. Keep a record of every notice and Telegram's response. Everything else stays the same: report every object, re-file with new evidence, and block the links fakes send people to.

Frequently asked questions

Is Telegram covered by the Digital Services Act?

Yes, by the baseline rules for hosting services and online platforms. It isn't designated as a Very Large Online Platform, so the strictest obligations don't apply.

Would VLOP status make takedowns faster?

Not directly. VLOP status adds risk assessments, audits and transparency duties. It doesn't set a deadline for individual reports.

Is this legal advice?

No. Ask counsel how the DSA applies to your company's notices.

See which Telegram fakes are targeting your EU customers today with a free scan.

Sources

Accessed October 2026. Platform rules and processes change; check each source for the latest.

• European Commission: Digital Services Act

• European Commission: supervision of designated VLOPs and VLOSEs

• European Parliament question E-001293/2025

• Euronews: Telegram and the DSA threshold (Aug 2024)