Telegram reduces reported user numbers to avoid stricter EU regulation

How Telegram positions itself under EU law

Telegram is deliberately downplaying the number of its users in the European Union in order to avoid being classified as a “very large online platform” under the EU Digital Services Act (DSA). According to investigative journalists, the company insists that it is primarily a messenger rather than a social media platform, which allows it to remain outside the most demanding regulatory framework. This positioning is crucial, as legal status directly determines the level of regulatory oversight.

Under the DSA, platforms with more than 45 million monthly active users in the EU fall under direct supervision of the European Commission. Such platforms must comply with strict rules on transparency, content moderation, systemic risk assessments, and cooperation with regulators. Telegram argues that these thresholds should not apply to its service model, which it presents as private communication infrastructure rather than a public information platform.

Selective counting of users

In official correspondence with Belgian regulators, Telegram stated that for DSA purposes it counts only users who are active in public channels and groups. By excluding private groups and one-to-one chats, the company significantly lowers its reported audience size in Europe. This methodology plays a key role in keeping Telegram below the regulatory threshold.

However, regulators question this logic. While WhatsApp limits group chats to 1,024 participants, Telegram allows so-called “private” groups with up to 200,000 members. Such scale blurs the line between private communication and public broadcasting. Studies show that a large share of Telegram engagement occurs precisely in these large groups, which often function as news hubs or discussion forums.

Why the numbers matter

Globally, Telegram reports more than 800 million monthly active users, up from around 500 million just three years ago. Market analysts estimate that 10–15% of Telegram’s audience may be located in the EU, potentially exceeding the DSA threshold if broader activity metrics were applied.

Legal experts warn that reclassification would impose substantial compliance costs and higher liability risks. The upcoming decision by EU authorities may not only affect Telegram but also set a precedent for how hybrid messaging platforms are regulated across Europe.