The European Commission has designated ChatGPT as a very large search engine and Reddit and Roblox as very large online platforms under the DSA.
The three services declared that they reach at least 45 million average monthly users in the EU, meeting the threshold that triggers designation under the regulation.
Following notification of the designations, ChatGPT, Reddit, and Roblox have four months, until the end of December 2026, to comply with the additional obligations that the DSA places on VLOPs and VLOSEs. These include assessing and mitigating systemic risks linked to their services and algorithmic systems, covering areas such as the dissemination of illegal content, negative effects on minors, users' physical and mental well-being, fundamental rights, electoral processes, and public security. The three services were already subject to the general obligations that apply to online platforms and search engines under the DSA.
With the designations in place, the Commission gains investigative powers to examine the functionalities underpinning these services and any related systems. The Commission will supervise compliance in cooperation with national Digital Services Coordinators: Coimisiún na Meán, the coordinator for Ireland, will work alongside the Commission on ChatGPT and Reddit, both established in that country, while the Authority for Consumers and Markets (ACM), the coordinator for the Netherlands, will do so for Roblox, which is established there.
How the services qualify under the DSA
ChatGPT is classified as a hybrid service under the DSA. As an artificial intelligence system that can respond to user prompts and queries, including by searching the web, it meets the criteria for an online search engine. Reddit, a discussion-based platform organised around topic-specific communities, and Roblox, an immersive gaming and creation platform where users can build, publish and play games developed by other users, both qualify as online platforms because they enable users to disseminate third-party content publicly.
The three designations bring the total number of very large online platforms and search engines designated under the DSA to 28. The regulation divides supervisory and enforcement responsibility between the Commission and the network of Digital Services Coordinators, which handle enforcement and supervision at the level of individual EU member states. The addition of an AI-driven search tool such as ChatGPT to the list reflects the DSA framework's application to services built on generative AI where those services incorporate search functionality, alongside more established categories of social platforms and gaming environments.
