EU designates ChatGPT, Reddit and Roblox for stricter DSA oversight

The European Commission on Monday classified ChatGPT as a Very Large Online Search Engine and Reddit and Roblox as Very Large Online Platforms under the Digital Services Act, citing their reported monthly active user bases of at least 45 million each in the European Union. The designations place the three services under enhanced regulatory scrutiny four months from the official notification date, establishing a hard compliance deadline of December 31, 2026, by which time they must fully implement the additional obligations, according to the Commission.

Risk mitigation obligations

The newly designated services must now conduct comprehensive assessments and mitigate systemic risks linked specifically to the dissemination of illegal content, potential negative effects on minors, measurable impacts on users' physical and mental well-being, threats to fundamental rights, risks to electoral processes and broader challenges to public security. These specific obligations extend significantly beyond the general DSA requirements already applicable to the three platforms as standard online services and search engines, representing a substantial intensification of regulatory burden.

Commission oversight and enforcement

"These new designations mean that ChatGPT, Reddit and Roblox will now be held to a higher standard of scrutiny and accountability in the European Union, in line with their large impact on our citizens and society," Henna Virkkunen, the Commission's executive vice president for Tech Sovereignty, Security and Democracy, said. "We continue to watch the digital landscape closely and will not hesitate to designate any platform that meets the threshold for enhanced supervision under the Digital Services Act," she added. The Commission will supervise compliance in close cooperation with Ireland's Coimisiun na Mean for both ChatGPT and Reddit, while the Netherlands' Authority for Consumers and Markets retains primary oversight responsibility for Roblox.

Platform categorization and scope

The Commission determined that ChatGPT specifically qualifies as an online search engine under the DSA legal framework because it responds to user prompts and queries by actively searching the indexed web and returning synthesized results, whereas Reddit operates as a discussion-based platform where users create, share and interact with content in topic-based communities and Roblox enables users to create, publish and play games developed by other community members. Reddit and Roblox specifically qualify as online platforms because they facilitate the public dissemination of third-party content to wide audiences, the Commission noted. With these latest additions, the Commission has now designated 28 very large online platforms and search engines under the DSA, with supervision and enforcement responsibilities shared between Brussels and national Digital Services Coordinators across all EU member states.