Summary

• The European Commission has designated ChatGPT as a Very Large Online Search Engine and Reddit and Roblox as Very Large Online Platforms.
• Each service reported at least 45 million average monthly EU users, triggering additional Digital Services Act obligations.
• The companies now face systemic-risk assessments, independent audits, researcher-access duties, and stronger Commission supervision.

The European Commission has brought ChatGPT, Reddit, and Roblox into the strictest tier of the Digital Services Act, extending a regulatory regime built around Europe’s largest digital intermediaries to one of the world’s most widely used generative AI services.

ChatGPT has been designated a Very Large Online Search Engine, or VLOSE, while Reddit and Roblox have been designated Very Large Online Platforms, known as VLOPs. All three told the Commission that they reach at least 45 million average monthly users in the European Union, the threshold at which the DSA imposes additional obligations because of a service’s scale and potential systemic effects.

Following notification, the services have four months — by the end of November 2026, according to the Commission — to comply with the enhanced regime. That includes assessing and mitigating systemic risks linked to illegal content, minors, physical and mental wellbeing, fundamental rights, electoral processes, and public security, alongside independent audits and additional transparency requirements.

The designation does not amount to a finding that any of the companies has broken European law. Instead, size brings a more demanding operating model and gives Brussels a direct supervisory role over obligations that go beyond the baseline rules applying to smaller platforms and intermediaries.

ChatGPT crosses into platform regulation

Reddit and Roblox fit relatively familiar regulatory categories because both operate large services through which users publish content and interact. ChatGPT presents the more consequential classification because the Commission has now placed a general-purpose AI service within the DSA’s search-engine framework at the same time as the EU develops a separate regulatory structure around artificial intelligence itself.

The boundary has been forming as conversational AI systems take on functions previously associated with search, information discovery, and content distribution. Techopia examined that emerging overlap in Europe tests where an AI platform begins, where regulatory attention was already moving towards the service users receive rather than simply the technical category attached to the underlying model.

The DSA and AI Act address different parts of that stack. The AI Act establishes obligations around artificial-intelligence systems and models, while the DSA deals with digital services, their interfaces, algorithmic systems, information flows, and the risks created when very large services mediate what people see and access online.

That distinction means ChatGPT can accumulate obligations under more than one European rulebook without either regime becoming redundant. Model governance can sit alongside requirements addressing how the finished service handles information, recommendations, risk assessment, transparency, and user protection.

Scale becomes an operational burden

Very large services must maintain a compliance apparatus rather than waiting for an investigation to expose weaknesses. The enhanced DSA regime requires recurring risk assessments and independent audits, while regulators gain additional powers to examine compliance and vetted researchers can obtain access to certain data needed to study systemic risks.

For services using recommender systems, the rules can also reach into product design, including requirements around profiling and transparency. Those provisions were conceived largely around social platforms and search businesses, but the inclusion of ChatGPT demonstrates how quickly generative AI is absorbing functions that make the older distinction between search engine, platform, and AI assistant harder to sustain.

The practical consequences will depend on the risk assessments and mitigation measures each service develops. Roblox’s exposure to younger users creates a different risk profile from Reddit’s community model, while ChatGPT raises questions around information discovery, generated responses, model behaviour, and the ways users increasingly substitute conversational systems for conventional search.

European regulators have also moved beyond merely designating large services. DSA supervision now includes formal investigations, information requests, commitments, and enforcement proceedings across a range of companies, making the designation a starting point for continuing regulatory scrutiny rather than an administrative label that can be dealt with once and filed away.

OpenAI will consequently have to operate ChatGPT inside overlapping European regimes at a time when AI assistants are moving deeper into workplace software, education, research, and everyday information retrieval. Reddit and Roblox face a more established platform framework, although moderation, recommendation, child safety, and researcher access give each company a distinct compliance workload.

As AI services acquire audiences once associated mainly with the largest search engines and social networks, Brussels is beginning to regulate them according to the function and reach they possess in the market. The four-month compliance period will now show how far that shift reaches into the design and governance of ChatGPT itself.