---
title: "EU plan would let users switch off the streaks Duolingo's paywall now runs on"
description: "The EU's Digital Fairness Act would let consumers switch off streaks days after cheap AI models destroyed Duolingo's ability to charge for its best feature, leaving gamified friction to carry the paywall that Brussels now targets and shareholders are suing over."
publisher: "The Inference"
section: "Applications"
published: 2026-11-12T16:25:29.244Z
modified: 2026-11-12T16:25:29.244Z
canonical: https://theinference.org/article/eu-plan-would-let-users-switch-off-the-streaks-duolingo-s-paywall-now-runs-on
language: en
keywords: "Duolingo, Digital Fairness Act, European Union, Consumer Apps, Gamification"
---

# EU plan would let users switch off the streaks Duolingo's paywall now runs on

> The EU's Digital Fairness Act would let consumers switch off streaks days after cheap AI models destroyed Duolingo's ability to charge for its best feature, leaving gamified friction to carry the paywall that Brussels now targets and shareholders are suing over.

Brussels [proposed the Digital Fairness Act on November 11](https://iapp.org/news/a/european-commission-releases-draft-proposal-for-digital-fairness-act), and one provision lands squarely on [Duolingo](https://theinference.org/markets/companies/duolingo): consumers would get the right to switch off addictive design, streaks included, alongside a ban on dark patterns and fines up to 6% of worldwide annual turnover [1][2]. This is a proposal, not law. But it arrives days after Duolingo said an AI conversation now costs well under a penny and announced it is killing its top subscription tier [3]. When the AI feature stops being the premium, what is left to charge for is the friction, and friction is exactly what Brussels wants switchable and what shareholders are litigating.

## An AI tutor got too cheap to charge for

Duolingo's AI Video Call, the conversation practice with the animated character Lily, cost about 30 cents per call at launch [3]. Cheaper open-weight models cut that to well under a penny, so Duolingo [stops selling new Max subscriptions this month](https://observer.com/2026/11/luis-von-ahn-duolingo-max-super-ai-subscriptions/) and brings unlimited Video Call to every Super subscriber by year-end; management calls the bookings effect minimal [3].

For learners this is the chain working as it should: cheap models turn a premium feature into a baseline one. The cost lands one hop up. Duolingo must now convert free users into payers without the AI paywall, and [the quarter it just reported](https://www.marketscreener.com/news/duolingo-q3-2026-financial-results-shareholder-letter-ce785fdedc88f12c) shows the gap it has to close.

*Chart: **Duolingo's users grew twice as fast as its paying subscribers** Column chart of Duolingo's average daily active users and paid subscribers at quarter's end, in millions: daily users rose from 50.5 million in Q3 2025 to 64.9 million in Q3 2026, while paid subscribers rose from 11.5 million to 13.1 million, so the payer bar stays less than a fifth of the user bar and the gap widened.*

*Average daily active users and paid subscribers at period end, in millions, Q3 2025 against Q3 2026. Source: Duolingo's Q3 2026 shareholder letter. [4]*

## The paywall moves back to friction

Daily users grew 29% year over year in Q3, accelerating from 23% the quarter before; paid subscribers grew 14% [4][5]. Users are outrunning payers, and the company's plan leans harder on engagement mechanics: longer free trials, more advertising, in-app purchases, and collection events built on streak-style retention [4][5].

*Chart: **Revenue growth has fallen for six straight quarters and the margin has gone with it** Line chart of Duolingo's revenue growth and operating margin by quarter from Q4 2024 to Q3 2026. Year-over-year revenue growth peaked at 41.5% in Q2 2025 and fell to 13.7% in Q3 2026; operating margin rose from 4.6% to 15.3% in Q1 2026, then fell to 7.8% by Q3 2026.*

*Year-over-year revenue growth and operating margin, percent, by quarter. Operating margin is operating income as a share of revenue. Source: Duolingo quarterly figures from its SEC filings, retrieved 12 November 2026. [8]*

That is the same friction [the securities class action](https://theinference.org/article/a-pension-fund-sues-duolingo-over-ai-course-content-as-the-founder-sells-42-million-of-stock) targets. The complaint alleges Duolingo's Energy system and relentless upsells hurt users while management called the impact "relatively small"; the stock fell from about $260 in November 2025 to $101 by late February 2026, and [the lead-plaintiff deadline is December 7](https://www.prnewswire.com/news-releases/duol-deadline-alert-levi--korsinsky-reminds-duolingo-inc-duol-investors-of-securities-class-action-deadline-on-december-7-2026-302936691.html) [6].

## Brussels has the muscle, but the calendar is Duolingo's

The Commission has already proven enforcement: it found TikTok and [Meta](https://theinference.org/markets/companies/meta) in breach of the Digital Services Act's addictive-design rules this summer, under the same 6% ceiling [1]. The streak switch-off is the new part, and Duolingo's EU exposure is only one region.

The binding constraint is closer to home. Duolingo shares closed at $163.84 on November 11, up 4.5% on the post-earnings momentum [7]. Do not read that rally as the all-clear. The 2027 monetization push rests on the very mechanics now under review in Brussels and in a Pennsylvania courtroom, and the company [delivers its 2027 outlook with the February results](https://www.msn.com/en-us/money/general/duolingo-plans-monetization-push-in-2027-after-strong-user-growth/ar-AA2gJf1M) [7].

When the premium feature costs a penny, what you are really paying for is the friction, and that guide is the number that tests whether the friction holds.

## Takeaway

Cheap AI made Duolingo's best feature too cheap to sell, so the paywall now leans on streaks and friction, the exact design Brussels wants users to be able to switch off.

## Sources

1. [WIRED, Duolingo, Strava, and Ticketmaster Are All Caught Up in EU's New Digital Fairness Rules, 11 November 2026](https://www.wired.com/story/duolingo-strava-and-ticketmaster-are-all-caught-up-in-eus-new-digital-fairness-rules/)
2. [IAPP, European Commission releases draft proposal for Digital Fairness Act, 11 November 2026](https://iapp.org/news/a/european-commission-releases-draft-proposal-for-digital-fairness-act)
3. [Observer, Duolingo's Luis von Ahn Phases Out Max, Expands A.I. Calls, 11 November 2026](https://observer.com/2026/11/luis-von-ahn-duolingo-max-super-ai-subscriptions/)
4. [Duolingo Q3 2026 Financial Results, Shareholder Letter (via MarketScreener), 3 November 2026](https://www.marketscreener.com/news/duolingo-q3-2026-financial-results-shareholder-letter-ce785fdedc88f12c)
5. [Benzinga (via MSN), Duolingo plans monetization push in 2027 after strong user growth, 4 November 2026](https://www.msn.com/en-us/money/general/duolingo-plans-monetization-push-in-2027-after-strong-user-growth/ar-AA2gJf1M)
6. [PRNewswire, Levi & Korsinsky reminds Duolingo investors of securities class action deadline, 11 November 2026](https://www.prnewswire.com/news-releases/duol-deadline-alert-levi--korsinsky-reminds-duolingo-inc-duol-investors-of-securities-class-action-deadline-on-december-7-2026-302936691.html)
7. [Traders Union, Duolingo surges 4.52% today to $163.84, 12 November 2026](https://tradersunion.com/news/stocks/show/4203805-duolingo-surges-4-52percent-today-to/)
8. [Duolingo, quarterly figures from its SEC filings, retrieved 12 November 2026](https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&CIK=0001562088)


---

EU plan would let users switch off the streaks Duolingo's paywall now runs on — The Inference. Canonical: https://theinference.org/article/eu-plan-would-let-users-switch-off-the-streaks-duolingo-s-paywall-now-runs-on