EU Brings ChatGPT, Reddit and Roblox Under Its Toughest Digital Services Rules

The European Commission has designated ChatGPT as a Very Large Online Search Engine and Reddit and Roblox as Very Large Online Platforms under the Digital Services Act after each service declared at least 45 million average monthly users in the EU. The move brings all three under stricter obligations on systemic risk, algorithmic systems, illegal content, minors, fundamental rights, elections and public security.

The European Union (EU) is widening the reach of its toughest digital rules, bringing ChatGPT, Reddit and Roblox into the highest tier of oversight under the Digital Services Act. The three services have crossed the threshold of at least 45 million average monthly users in the EU, triggering stricter obligations that go well beyond routine content moderation.

ChatGPT has been designated a Very Large Online Search Engine (VLOSE), while Reddit and Roblox have been classified as Very Large Online Platforms (VLOP). The distinction reflects how the services operate, but the regulatory logic is the same: once a service reaches enough users to shape information, behaviour and public discourse at scale, the EU expects it to manage broader systemic risks.

The companies now have until the end of December 2026 to comply with additional obligations covering illegal content, risks to minors, physical and mental well-being, fundamental rights, elections and public security. The move is significant not because these services were previously unregulated, but because their scale now places them under a more demanding form of scrutiny.

Size Is No Longer Just a Business Metric; It Is a Regulatory Trigger

The DSA's 45 million-user threshold turns audience scale into a legal dividing line. Once a platform or search service crosses that level, the EU treats its reach as large enough to create risks that cannot be managed solely through general rules applicable to smaller services. Expanding user numbers may strengthen commercial influence, but it also increases regulatory obligations, especially when algorithms, recommendation systems or search functions shape what millions of people see and interact with.

For Reddit and Roblox, the classification is relatively straightforward because both enable users to distribute third-party content to the public. Reddit does so through community-driven discussions, while Roblox allows users to create and publish games and experiences that other users can access.

ChatGPT presents a more novel regulatory case. The Commission describes it as a hybrid service because it can respond to user prompts while also searching the web, allowing it to qualify as an online search engine under the DSA rather than as a conventional social platform.

ChatGPT's Designation Shows How Regulation Is Expanding Beyond Traditional Platforms

The classification of ChatGPT is one of the more consequential aspects of the decision because it shows how existing digital laws are being applied to newer AI-based services. The DSA was not designed only around conventional social networks or search engines, and the Commission is now using its framework to cover systems that combine conversational AI with information retrieval.

Generative AI services do not function in the same way as traditional search tools. Users do not simply receive ranked links; they often receive synthesized responses, explanations and summaries, making the relationship between algorithms, source material and user understanding more complex.

The designation means the Commission considers its web-search functionality sufficient to bring it within the DSA's online search category, where systemic risks and algorithmic effects become central areas of regulatory attention.

The broader implication is that regulatory categories are becoming more flexible as digital services converge. AI systems can search, social platforms can host video and commerce, and gaming platforms can function as social spaces, making old distinctions between product types increasingly difficult to maintain.

The Focus Is Shifting From Individual Content to System-Wide Risk

The most important feature of the new obligations is their emphasis on systemic risk. The DSA is not concerned only with whether an individual piece of content is illegal; it also asks whether the design and operation of a service can create wider harms when used at scale. It includes risks to minors, users' physical and mental well-being, fundamental rights, electoral processes and public security. For designated services, the responsibility is therefore not limited to reacting after problems appear, but extends to assessing how algorithms, product features and distribution systems may contribute to those risks.

This creates a different regulatory challenge for each company. Reddit's risks may emerge through public discussions and content circulation, Roblox's through user-generated gaming environments, and ChatGPT's through conversational outputs, search-enabled responses and the systems that shape what information is surfaced.

The Commission will also gain investigative powers to examine the functionalities behind these services and, where relevant, related systems. That gives regulators a basis to scrutinize not only outcomes but also the technical and operational mechanisms through which those outcomes are produced.

The Real Test Will Be How Compliance Changes the Products

The designation itself is only the beginning. The more important question is how ChatGPT, Reddit and Roblox adapt their systems before the end-of-December deadline and what regulators consider adequate mitigation of systemic risks.

The Commission will supervise ChatGPT and Reddit in cooperation with Coimisiún na Meán in Ireland, while Roblox will be overseen in cooperation with the Authority for Consumers and Markets in the Netherlands. This shared structure places the enforcement process across both EU-level and national regulatory institutions.

For the companies, the challenge will be to show that their mitigation measures are proportionate to the risks created by very different digital environments. The same legal framework will now have to accommodate conversational AI, community-based discussion and immersive gaming without assuming that all three produce the same forms of harm.

The Commission has now designated 28 very large online platforms and search engines under the DSA, underscoring how rapidly the highest tier of EU digital regulation is expanding.