The European Commission announced that 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 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 months ending March 31, 2026 — well ahead of Reddit's 57.2 million and Roblox's 48 million.
What VLOP and VLOSE actually mean
Article 33 of the Digital Services Act creates a heightened supervisory tier for the largest online platforms and search engines. A service joins it by individual European Commission decision once it reports at least 45 million average monthly active users in the EU — roughly 10% of the EU's population, a threshold recalibrated as the population changes. What matters legally is the designation itself, not size alone. Once designated, a company has four months to comply with obligations layered on top of the DSA's baseline rules that every platform already follows:
- Annual systemic-risk assessments (Article 34) covering illegal content, harm to minors, users' physical and mental well-being, fundamental rights, elections, and public security
- Risk-mitigation measures (Article 35) tailored to what those assessments find
- Independent external audits, at least yearly (Article 37)
- A non-profiling recommender-system option users can switch to instead of a personalized feed (Article 38)
- A public, searchable advertising repository (Article 39)
- Data access for vetted researchers (Article 40)
- Public transparency reporting, including the risk-assessment and audit reports themselves (Article 42)
- Crisis-response protocols for extraordinary circumstances (Article 48)
The bigger structural change is who enforces all of this. Ordinary platforms answer to their national Digital Services Coordinator; VLOPs and VLOSEs are supervised — and can be fined — directly by the European Commission, with penalties of up to 6% of global annual turnover.
What actually changes, and by when
For ChatGPT, Reddit, and Roblox, that four-month clock runs to "the end of January 2027," per the Commission's announcement. One caveat on the date: some secondary reporting cites a December 2026 deadline instead. This post follows the Commission's press release, since it is the primary source, but the discrepancy is worth watching for a correction on one side or the other.
Designation also gives the Commission direct investigative powers over these services' functionalities and algorithmic systems. It exercises them 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.
Enforcement is already happening
These obligations are already being actively enforced against existing 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, inadequate researcher access to platform data, and an incomplete advertiser repository. It has also issued preliminary findings that TikTok breached the DSA through addictive design — infinite scroll, autoplay, push notifications, and highly personalized recommendations — and that both TikTok and Meta failed to give researchers adequate access to public data. The 6%-of-global-turnover ceiling would translate into a materially different number for OpenAI, Reddit, or Roblox than it did 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 compliance timeline, which pushed 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 they hit the same companies at nearly the same time. And they reflect the same posture from Brussels: services built around conversational AI don't get a lighter-touch category just because the technology is newer than the platforms the DSA was written for.