EU Brings ChatGPT, Reddit, and Roblox Under Its Toughest Digital Rules

Key Takeaways

• The European Commission has designated ChatGPT as a Very Large Online Search Engine (VLOSE) and Reddit and Roblox as Very Large Online Platforms (VLOPs) under the Digital Services Act, triggering significantly expanded obligations for all three services.
• The designations apply because all three services declared they reach at least 45 million average monthly users in the EU — the threshold for enhanced DSA supervision.
• The three services now have four months — until January 2027 — to comply with additional obligations, including assessing and mitigating systemic risks from their services and algorithms related to illegal content, harm to minors, mental wellbeing, fundamental rights, electoral processes, and public security.
• With 28 Very Large Online Platforms and Search Engines now designated, the Commission gains investigative powers to examine the systems and algorithms behind each service.

The European Commission designated ChatGPT, Reddit, and Roblox under the Digital Services Act on August 31st, 2026, triggering a new layer of obligations for all three services. 

ChatGPT has been classified as a Very Large Online Search Engine — a designation that reflects its hybrid nature as a system that responds to user queries and searches the web. 

Reddit and Roblox have been designated as Very Large Online Platforms. All three declared they reach at least 45 million average monthly users in the EU, clearing the threshold for enhanced DSA supervision.

The designations give the Commission investigative powers to assess the functionalities and algorithmic systems behind each service. 

Supervision will be shared between the Commission and national Digital Services Coordinators: Coimisiún na Meán in Ireland for ChatGPT and Reddit, and the Authority for Consumers and Markets in the Netherlands for Roblox. 

The three services have until January 2027 (four months from the date of designation) to comply with the additional obligations that apply to VLOPs and VLOSEs.

What the New Obligations Require

The DSA's enhanced tier isn't primarily about content removal. It's about systemic risk assessment, requiring platforms to identify, analyze, and mitigate the risks their services and algorithms create at scale.

The obligations that now apply to ChatGPT, Reddit, and Roblox include: assessing systemic risks from the dissemination of illegal content through their services; evaluating negative effects on minors; examining impacts on users' physical and mental wellbeing; assessing risks to fundamental rights, electoral processes, and public security; and providing meaningful transparency about how their algorithmic systems work. 

They're also subject to independent audits and must give the Commission access to their systems and data for compliance assessments.

The ChatGPT designation is worth pausing on. Classifying an AI system as a search engine rather than a platform reflects the Commission's view that ChatGPT functions as a primary information retrieval tool for millions of users — one that shapes what people understand to be true about the world through its responses. 

That's not the traditional search engine framing, but it captures something important about how AI assistants are being used in practice, and it brings them under obligations around accuracy, transparency, and systemic risk that wouldn't apply to a simple chatbot designation.

The Broader DSA Picture

The Commission has now designated 28 VLOPs and VLOSEs in total. The list already includes Meta's platforms, TikTok, YouTube, X, Google Search, and others. ChatGPT, Reddit, and Roblox are meaningful additions for different reasons.

Reddit represents the largest discussion-based platform in the EU that hadn't yet faced VLOP-level obligations — its community-driven content model, which relies heavily on user moderation, now faces a systematic risk assessment requirement that’ll test how well that model handles the harms the DSA is targeting. 

Roblox brings child safety directly into focus: a platform where the user base skews heavily toward minors, now explicitly required to assess and mitigate risks to that demographic.

And ChatGPT's designation signals that the EU isn’t going to treat AI systems as a separate category exempt from the DSA's reach. 

The same framework that applies to social media platforms will apply to AI services that reach the same scale — including the obligation to assess how their algorithmic outputs affect elections, fundamental rights, and the information environment.

Vice-President Henna Virkkunen said the Commission "will not hesitate to designate any platform that meets the threshold for enhanced supervision." With 28 designations and counting, that statement is being backed by action.