The European Commission announced Monday that OpenAI's ChatGPT, along with Reddit and Roblox, will face stricter regulatory oversight under the Digital Services Act (DSA). ChatGPT has been classified as a Very Large Online Search Engine (VLOSE), while Reddit and Roblox are designated as Very Large Online Platforms (VLOPs). These designations apply to digital services with over 45 million average monthly users in the European Union, a threshold all three companies reported exceeding.
OpenAI reported 159 million monthly active users for ChatGPT in the EU over the six months ending March 2026. Reddit reported 57.2 million users, and Roblox approximately 48 million. The Commission's decision formalizes a move signaled in late July and means these services must comply with additional DSA obligations within four months, by the end of December 2026 or January 2027.
The DSA imposes a tiered regulatory framework, with VLOPs and VLOSEs facing the most extensive requirements due to their significant societal impact. These obligations include conducting annual systemic risk assessments to address issues such as illegal content, the protection of minors, potential negative effects on users' physical and mental well-being, fundamental rights, electoral processes, and public security. Designated services must also submit to independent audits and provide data access to regulators and vetted researchers.
Henna Virkkunen, Executive Vice-President for Tech Sovereignty, Security and Democracy at the European Commission, stated that the new designations mean ChatGPT, Reddit, and Roblox will be held to a higher standard of scrutiny and accountability in the EU. Non-compliance with the DSA can result in fines of up to 6% of a company's global annual turnover. The DSA has already led to approximately €870 million in fines, including penalties against AliExpress, Temu, and X.
The classification of ChatGPT as a Very Large Online Search Engine is notable. The Commission views ChatGPT as a "hybrid service" that qualifies as an online search engine because it can engage with and respond to user prompts and queries, including by searching the web. This brings a generative AI chatbot under a regulatory regime traditionally applied to services that index and direct users to existing web pages. This distinction raises questions about how search-related audit regimes will apply to a system that generates original text rather than merely retrieving information.
OpenAI has previously stated its commitment to safety, transparency, and accountability, and outlined its approach to DSA compliance, including mechanisms for reporting illegal content and transparency reporting. The company has designated its Government Request Portal (Kodex) as its point of contact for communications with EU authorities.
The DSA, which entered into force in 2022, aims to establish a comprehensive legal framework for digital services across the EU, updating the Electronic Commerce Directive 2000. It sets out rules for regulating online platforms and search engines generally, with enhanced duties for the largest services. The first group of VLOPs and VLOSEs was designated in April 2023, with compliance required from August 2023. The addition of ChatGPT, Reddit, and Roblox brings the total number of designated very large online platforms and search engines to 28.
The Commission's designations grant it investigative powers to assess the functionalities of these services and their related systems. The supervision of compliance will occur in cooperation with national Digital Services Coordinators. Ireland's Coimisiún na Meán will work with the Commission on ChatGPT and Reddit, while the Netherlands' Authority for Consumers and Markets will oversee Roblox. This move follows the AI Act's content-labeling and watermarking rules taking effect a month prior, further expanding the EU's regulatory reach into generative AI.