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The European Union is planning to include ChatGPT and Roblox within its definition of very large online platforms (VLOPs), according to reports from Bloomberg.[1]
Under the Digital Services Act (DSA), platforms and search engines with more than 45 million monthly users are classified as VLOPs.
This is a pro-privacy move, as it would require the two companies — which are infamous for operating in grey areas — to tighten several user privacy measures, including regular risk assessments, better transparency, external audits, and protecting kids from targeted advertising.
The changes are expected to come into force as early as August. Here's a detailed look into what they mean for the businesses and why there are reasons beyond just an expanding user base for their inclusion under the DSA.
What does the VLOP classification imply
Increasing litigation against the companies
The DSA has a strong enforcement record
Bottom line
Do ChatGPT and Roblox qualify?
Yes. According to their own disclosures, both companies exceed the DSA's 45 million monthly user threshold.
- ChatGPT had approximately 159.1 million average monthly active users in the European Union during the six-month period ending March 31, 2026.
- Roblox had 48 million average monthly active users in the EU during the six-month period ending February 13, 2026.
What does the VLOP classification imply
According to Bloomberg, the VLOP status is not just another classification, but it triggers several rules that businesses must comply with.
These rules are aimed at tackling the risks that such large platforms might pose to the safety of their European users, including the regulation of illegal content, ad transparency, and health and safety.
Core requirements for VLOPs under the DSA include:
- They must conduct annual systematic risk assessments covering content integrity and civic discourse.
- They must establish a point of contact for authorities and users, report criminal offenses that they become aware of, publish regular transparency reports, and create user-friendly terms and conditions while fully disclosing their risk mitigation plans.
- They must undergo annual independent external audits to assess their degree of compliance with DSA obligations.
- They must allow vetted researchers to access data to help detect and understand systemic risks in the EU. They’re also required to share data with regulators for compliance purposes.
- They must maintain a publicly available repository of advertisements and refrain from profiling-based ad targeting, instead offering a recommender system option.
- They’re specifically barred from using targeted advertising when it involves minors' data. The platforms must provide the highest level of privacy and security for minors by default.
- Lastly, they must also pay an annual supervisory fee, which cannot exceed 0.05% of their annual worldwide net income, to fund the European Commission's oversight work.
ChatGPT and Roblox will have four months to comply with the DSA requirements post-classification. Failure to comply with these and other VLOP requirements may lead to fines of up to 6% of their global annual turnover.
Increasing litigation against the companies
While both Roblox and ChatGPT meet the average monthly user requirement to be included in the VLOP classification, there may be other reasons why the EU considers increased oversight of these companies important, especially in the case of Roblox.
The gaming company has been facing more than 100 individual lawsuits alleging child sexual exploitation and abuse.
The various plaintiffs allege that the platform acts as an initial point of contact between predators and children, after which the conversations are gradually moved to other messaging apps to escalate grooming and abuse. For example:
- A lawsuit was filed in Nebraska alleging that Roblox knowingly created and maintained an environment exposing millions of children to violent content, sexual predators, and illegal activities.
- Los Angeles County filed a lawsuit against the company, alleging that the platform has become a place where children face grooming and exploitation.
- Amid a slew of such lawsuits, Roblox reached a $12.2 million settlement with Alabama and an $11 million settlement with West Virginia in May 2026.
- Similarly, in April, the company agreed to pay $12.5 million to settle litigation in the state of Nevada.
Earlier in June, Florida filed a lawsuit against OpenAI and its CEO, Sam Altman, accusing the company of marketing ChatGPT as a safe and reliable platform, including for children, while allegedly failing to warn users about its potential dangers.
The complaint cites the case of Adam Raine, a 16-year-old teenager who died by suicide after extensive conversations with ChatGPT. The complaint also refers to the mass shooting at Florida State University, where the shooter allegedly used ChatGPT to plan the attack.
Against this backdrop of mounting legal scrutiny in the US, the EU's push to bring both platforms under its strictest oversight regime reflects a broader effort to ensure European users, particularly children, are not exposed to similar risks.
The DSA has a strong enforcement record
It’s worth noting that the DSA is known to take action even against large corporations when it comes to user safety and compliance.
In one of its first landmark decisions, the European Commission fined Elon Musk's X €120 million for following deceptive design practices, providing inadequate ad transparency, and blocking researchers' access to public data.
Similarly, AliExpress was fined €550 million in July 2026, the biggest fine ever imposed by the Commission. This was due to the ecommerce giant's failure to detect illegal products on its platform for weeks.
The Commission also alleged that AliExpress's penalty policy was ineffective, and that it allowed penalized sellers to continue selling illegal products on the platform.
Bottom line
The EU seems to have caught on to the increasing scrutiny ChatGPT and Roblox are facing in the United States, with several allegations that they do very little to protect children from online abuse.
Though both companies officially meet the 45 million minimum monthly user threshold to become VLOPs, this move is arguably rooted more in the EU wanting them to adopt greater transparency and stronger safety standards, particularly when it comes to protecting children.