Key Takeaways
- The European Commission designated OpenAI‘s ChatGPT as a Very Large Online Search Engine (VLOSE) and Reddit and Roblox as Very Large Online Platforms (VLOPs) on August 31, 2026, making ChatGPT the first standalone AI service to receive a DSA designation of this kind.
- All three platforms, each reporting over 45 million monthly EU users, must complete systemic risk assessments and implement mitigation measures by the end of November 2026, with fines of up to 6% of global annual turnover for non-compliance.
- The EU General Court’s rejection of Amazon’s and Zalando’s VLOP designation challenges in 2025 sets a clear legal precedent: courts have so far declined to limit the Commission’s authority to designate and impose obligations on large online services. ChatGPT is now regulated as a search engine under EU law. The European Commission formally designated OpenAI’s ChatGPT as a Very Large Online Search Engine under the Digital Services Act on August 31, 2026, the first time a standalone AI service has received that classification. Reddit and Roblox were designated Very Large Online Platforms on the same date, bringing the total number of strictly regulated EU digital services to 28.
Why These Three Platforms
The DSA’s heightened regime applies to platforms and search engines reporting more than 45 million average monthly active users in the EU. ChatGPT, Reddit and Roblox each crossed that threshold. ChatGPT’s classification as a VLOSE reflects its capacity to respond to user prompts and retrieve information from the web, functions the Commission treats as search-adjacent rather than purely generative. Reddit and Roblox were designated as VLOPs because both enable the public dissemination of third-party content.
The existing roster of designated services includes Amazon Apple, Google, Meta, Microsoft and TikTok. Henna Virkkunen, the Commission’s executive vice-president for Tech Sovereignty, Security and Democracy, said the new designations mean ChatGPT, Reddit and Roblox will face scrutiny and accountability commensurate with their impact on EU citizens.
Compliance Deadlines
The three platforms have until the end of November 2026 to meet the additional DSA obligations that come with designation. The core requirement is a systemic risk assessment covering potential harms tied to their services and algorithmic systems. Under Article 34(1) of the DSA, that assessment must address four categories: the spread of illegal content, adverse effects on fundamental rights, threats to civic discourse and electoral integrity, and risks to public health, well-being and the protection of minors.
Beyond the risk assessment itself, platforms must introduce user-facing transparency measures: clear terms and conditions, accessible points of contact for authorities and users, and transparent reporting of criminal offences. VLOPs and VLOSEs must also offer non-personalised content feeds, ban targeted advertising to minors, and prohibit ad targeting based on sensitive personal data such as sexual orientation or religion. Enforcement will be split between national Digital Services Coordinators: Ireland’s Coimisiún na Meán will oversee ChatGPT and Reddit, while the Netherlands’ Authority for Consumers and Markets is responsible for Roblox.
Systemic Risk in Practice
The DSA does not define “systemic risk” with precision, which places the analytical burden squarely on platforms. Compliance requires investment in engineering and data infrastructure. Platforms must open data access to vetted researchers, commission independent annual audits of their DSA obligations, and establish independent compliance bodies to manage systemic risk on an ongoing basis. For a service like ChatGPT, where an AI model drives both content generation and information retrieval, the algorithmic transparency requirements are particularly demanding. Sarah Eskens, a digital legislation researcher at VU Amsterdam has noted that the DSA requires platforms to be transparent about how they moderate content, particularly as AI systems take on more of that function automatically.
The non-personalised feed requirement directly challenges default platform practices. Many large services prioritise algorithmically personalised content to drive engagement and advertising revenue; the DSA now requires that EU users have a meaningful alternative.
The Cost Reality
DSA compliance carries material costs. A 2025 study from the CCIA Research Center estimated that EU digital regulations could impose up to $97.6 billion annually in costs and revenue losses on US companies, with the DSA alone accounting for an estimated $750 million in annual direct compliance costs across designated services. Those figures cover legal fees, risk assessments, transparency reporting and the translation of terms and services into all EU languages.
The sharper financial exposure, though, is enforcement. Platforms that fail to meet DSA obligations face fines of up to 6% of global annual turnover. The Commission has already imposed roughly €870 million in fines: €550 million against AliExpress, €200 million against Temu and €120 million against X. For the newly designated trio, those precedents are the more relevant number.
Legal Challenges So Far
Several platforms have contested their designations in court. Amazon challenged its VLOP status in the EU General Court in 2025, arguing its marketplace operations did not generate systemic risks comparable to those of social media or search services, and that the obligations imposed were disproportionate. The court rejected that argument, ruling that online marketplaces do give rise to systemic risk and that scale alone justifies enhanced due-diligence requirements. Zalando’s challenge was dismissed on similar grounds in September 2025. Meta, TikTok and Google have also initiated legal proceedings over DSA regulation fees for 2024.
The courts have consistently upheld the Commission’s authority to designate large online services and impose stringent obligations. That record matters for ChatGPT, Reddit and Roblox: the legal route has not, to date, offered designated platforms a way out.
The Brussels Effect on AI
ChatGPT’s designation as the first standalone AI service classified as a VLOSE is the clearest signal yet that the EU intends to apply DSA obligations to AI-driven services, not just conventional platforms. The practical consequence is that OpenAI must build systemic risk assessment, algorithmic transparency and user protection into ChatGPT’s EU operations to a standard the Commission can audit and, if necessary, fine against.
The broader question is whether DSA compliance shapes how OpenAI designs its service globally. Multinational companies frequently apply a single compliance standard across jurisdictions rather than segment by market, a dynamic sometimes described as the “Brussels Effect.” Critics argue the DSA’s content moderation and algorithmic accountability requirements could raise costs and constrain product decisions for US firms operating in the EU. Proponents counter that the requirements push development of better content filters, more rigorous age verification and more auditable AI systems. The EU’s AI Act’s GPAI provisions are heading in a similar direction, and the two frameworks will increasingly interact for services like ChatGPT that fall under both.
Where DSA Regulation Goes Next
The Commission has stated it will continue monitoring the digital landscape and will designate any platform that crosses the 45 million monthly active user threshold. As more AI services achieve scale within the EU, designation under the DSA is a foreseeable compliance event rather than an exceptional one. The DSA, the Digital Markets Act and the AI Act are converging into a regulatory architecture that covers market power, systemic risk and model-level obligations across the same set of large digital services. The EU courts’ consistent rejection of designation challenges suggests that architecture is unlikely to be dismantled from within the legal system. For ChatGPT, Reddit and Roblox, November 2026 is the immediate deadline; the longer compliance arc is structural.
Originally published at https://autonainews.com/eu-designates-chatgpt-reddit-and-roblox-under-strict-dsa-rules/
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