EU places ChatGPT, Reddit and Roblox under its strictest digital oversight

The European Commission has placed ChatGPT, Reddit and Roblox under the highest level of supervision established by the Digital Services Act, expanding the regulation’s reach to conversational artificial intelligence, online communities and user-generated gaming platforms.

Brussels designated ChatGPT as a Very Large Online Search Engine, or VLOSE, while Reddit and Roblox were classified as Very Large Online Platforms, known as VLOPs.

The decision is based on the scale of their European audiences. Under the DSA, an online service enters the most heavily regulated category when it reaches at least 45 million average monthly users in the European Union, equivalent to approximately 10% of the bloc’s population.

The designation is not a penalty and does not mean that the Commission has determined that the companies breached European law. It activates a set of additional obligations intended for services whose scale and algorithmic systems can create risks extending beyond individual users.

The three companies will have four months from formal notification to comply with the new requirements.

ChatGPT’s classification is the most significant element of the decision because it applies rules developed for large information intermediaries to a generative artificial intelligence service.

The Commission described ChatGPT as a hybrid service capable of responding to prompts and queries while also searching the internet. That functionality allows it to qualify as an online search engine under the DSA, even though it normally presents information through generated answers rather than a traditional list of links.

OpenAI reported approximately 159.1 million average monthly active recipients of ChatGPT Search in the EU during the six months ending on 31 March 2026. The company specifies that the calculation relates to its online search functions and was prepared specifically for DSA compliance, meaning it should not be treated as a conventional commercial user metric.

Reddit reported no more than 57.2 million monthly active recipients in the EU during the first half of 2026. Roblox estimated that it reached 46.6 million during the six-month period ending in August, placing the gaming and creation service just above the legal threshold.

Reddit qualifies as a platform because its users create, distribute and discuss content within public communities. Roblox falls into the same regulatory category because users can develop, publish and access games and interactive experiences created by other members.

Once the new rules take effect, the companies will be required to identify, assess and mitigate systemic risks associated with their services and algorithmic systems.

The areas covered include the dissemination of illegal content, threats to fundamental rights, the protection of minors, users’ physical and mental well-being, gender-based violence, public security and the integrity of elections and civic debate.

These assessments must examine not only the content available through the services, but also the way algorithms, interfaces and product features may amplify or facilitate harmful outcomes.

The platforms will need to establish internal compliance functions, undergo an independent audit at least once a year and respond to the auditor’s recommendations. They must also provide regulators with the data required to evaluate compliance and grant approved researchers access to information relevant to the study of systemic risks.

Additional requirements include greater transparency around content moderation, advertising and recommender systems. Very large services must maintain public advertising repositories and, where recommendation systems are used, provide an option that is not based on profiling.

The practical consequences will differ across the three companies.

For OpenAI, the designation raises questions about how risks should be assessed when a system retrieves information, generates new text and responds differently to each user. Regulators may examine the operation of ChatGPT Search and, where legally relevant, the related systems supporting its answers.

The company will need to document how it handles illegal material, misleading information, risks affecting minors and potential effects on fundamental rights. Its compliance obligations under the DSA will operate alongside the separate requirements imposed on artificial intelligence providers by the EU AI Act.

For Reddit, the additional scrutiny will focus on the interaction between community moderation, corporate enforcement and recommendation algorithms. The company relies partly on volunteer moderators, but legal responsibility for the platform’s systems and compliance remains with Reddit.

The DSA does not require platforms to remove every disputed opinion. It requires accessible reporting mechanisms, explanations for moderation decisions, appeal procedures and measures against content that is illegal under European or national law.

For Roblox, the protection of children will be a central issue. The platform is widely used by minors and combines gaming, social interaction, virtual purchases and content produced by its community.

Its risk assessments may cover age assurance, communication between adults and children, exposure to inappropriate experiences, commercial design, recommendation systems and features that can encourage extended use or spending.

The Commission will obtain direct investigative powers over the designated services and, where applicable, their related systems. It will supervise ChatGPT and Reddit in cooperation with Coimisiún na Meán, Ireland’s Digital Services Coordinator, and Roblox alongside the Netherlands’ Authority for Consumers and Markets.

The choice of regulators reflects the companies’ European establishments. OpenAI and Reddit operate their relevant EU services from Ireland, while Roblox is established in the Netherlands.

Failure to comply with the DSA can result in fines of up to 6% of a company’s worldwide annual turnover. Repeated and serious violations can lead to further enforcement measures, although any sanction would require a separate investigation and findings of non-compliance.

OpenAI has stated that it is committed to safety, transparency, accountability and the protection of fundamental rights as part of its DSA preparations. Roblox has also said it is ready to work with the Commission and described safety as a core part of its operations. Reddit did not immediately provide a detailed public response to the designation.

The companies were already subject to the DSA’s general provisions. Their new status introduces the requirements reserved for services with the largest reach and places them under direct Commission supervision.

ChatGPT, Reddit and Roblox join a group that includes services operated by Google, Meta, Microsoft, Amazon, TikTok and X. With the latest additions, the Commission has designated 28 very large platforms and search engines.

The expansion illustrates how the European digital rulebook is moving beyond the social networks, marketplaces and conventional search engines that dominated the internet when the DSA was drafted.

ChatGPT’s inclusion is particularly important because it establishes that an AI assistant can be treated as part of the information-distribution infrastructure when its search function reaches sufficient scale.

For the companies, the designation will increase expenditure on auditing, risk management, engineering, legal work and regulatory reporting. It may also require changes to interfaces, recommendation systems and safety controls within the European market.

For users, the effects are likely to appear gradually through clearer moderation explanations, additional appeal options, greater advertising transparency and stronger safeguards for minors. The decision does not automatically require identity checks, introduce a subscription or restrict access to the three services.

The broader issue is whether regulations designed around platforms and search engines can be applied consistently to products that combine generated answers, online communities, entertainment and commercial ecosystems.

The Commission’s decision indicates that scale, rather than a company’s chosen product description, will determine the level of oversight. As digital services cross the 45 million-user threshold, the EU intends to examine not only what they publish, but also how their systems shape information, behaviour and risk.