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The European Union has officially placed ChatGPT, Reddit, and Roblox under the strictest tier of its Digital Services Act (DSA). In an August 31 announcement, the European Commission designated ChatGPT as a very large online search engine (VLOSE), and Roblox — along with Reddit — as very large online platforms (VLOPs).[1]
Under the DSA, services that reach more than 45 million average monthly users in the EU fall into this top tier. All three declared they cross that line. The designation brings obligations that go well beyond the DSA's baseline rules: annual systemic risk assessments, independent external audits, data access for outside researchers, and default privacy protections for minors.
All three services now have four months, until January 2027, to comply. Failure can bring fines of up to 6% of global annual turnover.
The designation brings the total number of very large platforms and search engines under direct Commission oversight to 28, a list that already includes Amazon, Apple, Google, Meta, Microsoft, and TikTok.
The most consequential detail is how ChatGPT was categorized. Reports ahead of the announcement, including from Bloomberg, anticipated it would be designated a very large online platform. Instead, the Commission treated it as a search engine.
Its reasoning: ChatGPT is an artificial intelligence system that can engage with and respond to users' prompts and queries, including by searching the web. That hybrid nature is what qualifies it as an online search engine under the DSA.
Reddit and Roblox landed in the other category. The Commission describes Reddit as a discussion-based platform where users create, share, and interact with content inside topic-based communities, and Roblox as an immersive gaming and creation platform where users publish and play games built by others. Because both let users distribute third-party content to the public, they qualify as online platforms.
The distinction matters more than it sounds. It is one of the first times a major regulator has had to decide what an AI chatbot legally is, and Brussels decided it belongs in the same bucket as a search engine. Every other regulator writing AI rules now has that precedent to work from.
All three services were already subject to the DSA's general obligations for online platforms and search engines. What changes is the added layer that comes with being designated very large.
The VLOP status 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:
While all three services meet the user threshold on paper, there are other reasons the EU has reason to want closer oversight, especially with 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:
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.
Reddit is not facing a comparable wave of child safety litigation, which is a useful reminder that the 45 million threshold is the trigger here, not scandal. But against the backdrop of mounting legal scrutiny in the US, the EU's move to bring ChatGPT and Roblox under its strictest regime reflects a broader effort to keep European users, particularly children, from facing the same risks.
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.
The EU has made it official, and the timing is hard to separate from the scrutiny ChatGPT and Roblox are facing in the United States over child safety. All three services cleared the 45 million threshold on their own numbers, so the designation itself was largely arithmetic. What matters is what comes with it: published risk assessments, independent audits, researcher access to data, and default protections for minors, all due by January 2027 and enforceable with fines of up to 6% of global revenue.
For ChatGPT there's a second story underneath the first. Being regulated as a search engine rather than a platform is the EU's first real answer to a question every regulator is circling: what is a chatbot, legally speaking? Brussels decided it's a search engine. That framing will follow the rest of the industry.
Updated August 31, 2026: The European Commission has formally designated ChatGPT, Reddit, and Roblox under the DSA. ChatGPT was designated as a very large online search engine, not a very large online platform as earlier reports anticipated. This article has been updated throughout.
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