- ChatGPT designated as VLOSE, Reddit and Roblox as VLOPs under the DSA, with a threshold of 45 million EU users.
- The three services have four months to comply with heightened risk-assessment obligations – deadline is 31 December 2026.
- Supervision is shared between the Commission and the digital authorities of Ireland and the Netherlands.
- ChatGPT qualifies as an online search engine because its AI system can search the web and respond to user queries.
- A total of 28 very large online platforms and search engines are now designated under the DSA.
Designation as Very Large Online Services
The Commission has designated ChatGPT as a Very Large Online Search Engine (VLOSE), as well as Reddit and Roblox as Very Large Online Platforms (VLOPs), under the Digital Services Act (DSA). All three services declared that they reach at least 45 million average monthly users in the EU, thus meeting the threshold for designation.
Four Months to Comply with Strengthened Rules
Following the notification of the designations, the three services have four months – until the end of December 2026 – to comply with the additional DSA obligations for VLOPs and VLOSEs, including:
- Assessing and mitigating systemic risks stemming from their service and algorithmic systems
- Dissemination of illegal content
- Negative effects on minors
- Users' physical and mental well-being
- Fundamental rights, electoral processes, and public security
Supervisory Powers Granted to the Commission and National Authorities
With these designations, the Commission will gain investigative powers to assess the functionalities behind these services and any related systems. Supervision of DSA compliance will be carried out in cooperation with:
| Service | Digital Services Coordinator | Country of Establishment |
|---|---|---|
| ChatGPT and Reddit | Coimisiún na Meán | Ireland |
| Roblox | Authority for Consumers and Markets (ACM) | Netherlands |
What Type of Service Is Each?
ChatGPT is an Artificial Intelligence (AI) system that can engage with and respond to users' prompts and queries, including by searching the web. It therefore qualifies as a hybrid service that is an online search engine under the DSA.
Reddit is a discussion-based platform that enables users to create, share, and interact with content within topic-based communities.
Roblox is an immersive gaming and creation platform that enables users to create, publish, and play games developed by other users.
Both qualify as online platforms under the DSA, as they enable users to disseminate third-party content to the public.
Background
The Commission has now designated 28 very large online platforms and search engines under the DSA in total. Supervision and enforcement are shared between the Commission and the national Digital Services Coordinators, who are responsible for enforcement of the Act in the Member States. All three services are already subject to the general obligations applicable to online platforms and search engines under the DSA.