The European Commission has designated ChatGPT as a Very Large Online Search Engine (VLOSE), as well as Reddit and Roblox as Very Large Online Platforms (VLOPs), under the Digital Services Act (DSA). These services declared that they reach at least 45 million average monthly users in the EU and thus meet the threshold for designation.
Following the notification of the designations, these services have four months, i.e. by the end of December 2026, to comply with the additional DSA obligations for VLOPs and VLOSEs, such as assessing and mitigating the systemic risks stemming from their service and algorithmic systems related to the dissemination of illegal content, the negative effects on minors, users’ physical and mental well-being, fundamental rights, electoral processes and public security.
With these designations, the Commission will gain investigative powers to assess the functionalities behind these services and, where applicable, any related system. The Commission will be competent to supervise compliance with the DSA, in cooperation with Coimisiún na Meán for ChatGPT and Reddit, and the Authority for Consumers and Markets (ACM) for Roblox. These entities serve as the Digital Services Coordinators respectively for Ireland and for the Netherlands, where the designated services are established.
ChatGPT is an Artificial Intelligence (AI) system that can engage with and respond to users’ prompts and queries, including by searching the web. Hence, ChatGPT is a hybrid service that qualifies as an online search engine under the DSA.
Reddit is a discussion-based platform that enables users to create, share, and interact with content within topic-based communities. Roblox is an immersive gaming and creation platform that enables users to create, publish, and play games developed by other users. As these services enable users to disseminate third-party content to the public, they qualify as online platforms under the DSA.
Roblox, Reddit and ChatGPT are already subject to the general obligations applicable to online platforms and search engines under the DSA, respectively.
The Commission has now designated 28 very large online platforms and search engines under the DSA.
The supervision and enforcement of the DSA is shared between the Commission and Digital Services Coordinators, which are responsible for the enforcement and supervision of the Digital Services Act in the Member States.
