The European Commission announced it has designated ChatGPT as a Very Large Online Search Engine (VLOSE) and Reddit and Roblox as Very Large Online Platforms (VLOPs) under the Digital Services Act, effective August 31, 2026. All three crossed the DSA's threshold of at least 45 million average monthly EU users on their own self-declared numbers — OpenAI reported roughly 159.1 million average monthly EU users for the six-month period ending March 31, 2026, ahead of Reddit's roughly 57.2 million and Roblox's roughly 48 million.
Why a chatbot counts as a search engine
The Commission's own classification logic is stated directly in its announcement: "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." That's a first — no AI chatbot has previously been designated a VLOSE — and it means the DSA's search-engine-specific obligations, not just its general platform obligations, now apply to ChatGPT specifically because of its web-search capability, not because of its conversational core. Reddit and Roblox were designated as VLOPs on more conventional grounds: both let users publish and share content or user-made experiences to the public, which is what qualifies a service as an online platform under the DSA rather than a search engine.
What actually changes, and by when
Per the Commission's announcement, the three companies have four months from notification — "by the end of January 2027" — to comply with the additional obligations that come with VLOP/VLOSE status: assessing and mitigating systemic risks tied to their service and algorithmic systems, specifically around illegal content, negative effects on minors, users' physical and mental well-being, fundamental rights, electoral processes, and public security. Worth flagging directly: some secondary reporting on this announcement states a December 2026 compliance deadline rather than the "end of January 2027" the Commission's own press release states explicitly — this post follows the Commission's own wording since it's the primary source, but the discrepancy is worth watching for a correction on one side or the other. Designation also hands the Commission direct investigative powers over these services' functionalities and algorithmic systems, supervised in cooperation with each company's home-country Digital Services Coordinator — Coimisiún na Meán for ChatGPT and Reddit, both established in Ireland, and the Authority for Consumers and Markets (ACM) for Roblox, established in the Netherlands.
The company this designation actually has teeth against
The DSA's systemic-risk and investigative obligations aren't new or theoretical — they're already being actively enforced against other VLOPs, which is the clearest signal of what ChatGPT, Reddit, and Roblox are now exposed to. The Commission fined X €120 million for three separate DSA breaches: deceptive "blue tick" verification practices, inadequate researcher access to platform data, and an incomplete advertiser repository. Separately, the Commission has issued preliminary findings that TikTok breached the DSA over addictive design elements — infinite scroll, autoplay, push notifications, and highly personalized recommender systems — and that both TikTok and Meta failed to provide researchers adequate access to public data as the DSA requires. The maximum penalty framework tops out at 6% of a company's global annual turnover, which for OpenAI, Reddit, or Roblox would be a materially different number than for X.
Where this sits in the wider EU AI regulatory push
This designation lands three weeks after the EU's Digital Omnibus on AI reshuffled the AI Act's own compliance timeline, pushing high-risk AI Act obligations to December 2027 while keeping chatbot-disclosure rules and AI Office powers on their original schedule. The two tracks are legally separate — this is a DSA designation, not an AI Act one — but both land on the same set of companies at nearly the same time, and both reflect the same underlying posture from Brussels: services built around conversational AI don't get a bespoke, lighter-touch category just because the underlying technology is newer than the platforms the DSA was originally written for.
What to expect next
- Watch for OpenAI's, Reddit's, or Roblox's own response. None of the three has been quoted reacting to the designation as of this announcement; how systemic-risk assessments for a chatbot's web-search function actually get built and audited is a genuinely open implementation question none of the DSA's existing VLOSE precedents (Google, Bing, and now ChatGPT) have fully worked through in public.
- Watch whether the compliance-deadline discrepancy gets resolved. The Commission's own release states end of January 2027; some secondary coverage states December 2026 — worth confirming which is accurate before treating either as settled.
- Watch whether other AI chatbots with web-search features cross the same 45-million-user threshold next, given the Commission has now established the classification logic (an AI system that can search the web is a "hybrid service" and a search engine under the DSA) as a precedent other regulators and companies can point to.
References: European Commission — Commission designates ChatGPT, Reddit, Roblox under Digital Services Act, read directly from the press release provided · Reddit and Roblox's reported EU user figures relayed from WebSearch summaries of secondary coverage, since this environment could not fetch the originating outlets directly to verify (egress to those domains is blocked) · related coverage: The AI Act's Compliance Cliff Just Got Deferred · Frontier Arcade: trends & predictions