EU AI Office · August 31, 2026
EU Commission Designates ChatGPT, Reddit, and Roblox as VLOPs/VLOSE Under the DSA
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, triggering enhanced systemic risk obligations by January 2027.
What Was Announced
On 31 August 2026, the European Commission designated ChatGPT as a Very Large Online Search Engine (VLOSE) under the Digital Services Act (DSA), and Reddit and Roblox as Very Large Online Platforms (VLOPs). According to the Commission, these services declared reaching at least 45 million average monthly users in the EU, which is the threshold triggering designation under the DSA.
Compliance Timeline and Obligations
Following notification of the designations, the three services have four months to comply with the additional obligations that apply to VLOPs and VLOSEs — meaning compliance is due by January 2027. The Commission specifies that these obligations include assessing and mitigating systemic risks arising from the service and its algorithmic systems, particularly in relation to:
- The dissemination of illegal content
- Negative effects on minors
- Impacts on users' physical and mental well-being
- Effects on fundamental rights
- Risks to electoral processes and public security
What This Means
For organizations operating or partnering with these platforms, this designation signals a shift into the DSA's most stringent compliance tier, with a concrete deadline of January 2027 for systemic risk assessment and mitigation measures. Legal, privacy, and trust & safety teams at ChatGPT, Reddit, and Roblox should prioritize risk assessment frameworks covering the specific harm categories identified by the Commission — illegal content, minor protection, well-being impacts, fundamental rights, and electoral/public security risks. Organizations that integrate with or rely on these platforms (e.g., through APIs, advertising, or embedded services) should also monitor how these entities implement their new obligations, as downstream compliance expectations and platform policies may shift as a result. Given the short four-month compliance window, affected companies should treat systemic risk assessment methodology and mitigation planning as an immediate priority rather than a longer-term project.