EU Labels ChatGPT, Roblox, and Reddit as 'Very Large' Under DSA

The European Commission has expanded the scope of its Digital Services Act (DSA) to include some of the world's most prominent AI and social platforms. On August 31, 2026, the Commission officially designated OpenAI's ChatGPT as a Very Large Online Search Engine (VLOSE), while Roblox and Reddit were designated as Very Large Online Platforms (VLOPs).

These designations are triggered by the services' scale. Under the DSA, the threshold for 'very large' status is at least 45 million average monthly active recipients within the European Union. Because these platforms have surpassed this user count, they are now subject to the most stringent tier of EU regulation. The Commission identified ChatGPT as a VLOSE specifically due to its hybrid functionality, which combines a conversational chatbot with live web search capabilities.

The Regulatory Framework

Under the DSA, VLOPs and VLOSEs must adhere to a rigorous set of transparency and safety obligations. These companies are now required to conduct comprehensive assessments of systemic risks their platforms may pose to society. To ensure compliance, they must submit to annual independent audits and open their internal data to vetted researchers for external scrutiny.

Furthermore, these platforms must provide a content recommendation system that does not rely on profiling. This shift moves the regulatory focus away from how a company markets itself—whether as a 'gaming' site or an 'AI' tool—and instead focuses on the actual functionality the service provides to the end user.

Why the Shift Matters

This move represents a significant evolution in how the EU regulates emerging technology. By ignoring industry labels and focusing on actual utility, the European Commission is forcing companies to be transparent about their algorithms, data handling, and advertising targeting.

For the industry, this creates a challenging implementation phase. Traditional DSA requirements, such as non-profiling recommendations, were designed for social media feeds and search results. Applying these same rules to the fluid, conversational nature of generative AI or the ephemeral data generated within gaming environments like Roblox presents a complex technical and legal hurdle for the companies involved.

What's Next

As these platforms move toward full compliance, the primary point of friction will be the practical application of these rules to non-traditional interfaces. While the designations are now official, the industry will be watching how the Commission handles the specific technical challenges of auditing AI-driven search and gaming-based social networks. It remains to be seen how OpenAI, Reddit, and Roblox will adapt their internal architectures to meet these transparency mandates without compromising their core product experiences.