Privacy & Cybersecurity Law Blog

On August 31, 2026, the European Commission announced that it had 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 (“DSA”). The DSA classifies platforms or search engines with more than 45 million average monthly users in the European Union as VLOPs or VLOSEs, respectively. According to the European Commission, each of the three services met the relevant threshold.

The DSA imposes a stricter compliance regime on VLOPs and VLOSEs than on other online platforms and search engines. In general terms, a VLOP is an online platform with a very large EU user base that disseminates information or content to the public, while a VLOSE is a search engine with a comparably large reach in the EU. These categories are intended to capture services whose scale gives them a heightened capacity to shape public discourse, influence user behaviour, and amplify systemic risks across the EU internal market. Once a service is designated as a VLOP or VLOSE, it becomes subject to additional obligations beyond the DSA’s baseline rules.

The European Commission stated that ChatGPT qualifies as a hybrid service that falls within the DSA’s VLOSE category because it can search the web in response to user prompts. Reddit and Roblox were designated as VLOPs because they enable users to disseminate third-party content to the public. Reddit does so through user posts and discussions, while Roblox allows users to create, publish, and play games developed by other users.

Following designation, ChatGPT, Reddit, and Roblox have four months, until January 2027, to comply with the additional DSA requirements for very large services. Those obligations include assessing and mitigating systemic risks related to illegal content, adverse effects on minors, users’ physical and mental well-being, fundamental rights, electoral processes, and public security. Previously, the three services were already subject to the DSA’s general rules.

The designation also gives the European Commission supervisory and investigative authority over these services under the DSA. The Commission will oversee compliance in cooperation with the relevant national Digital Services Coordinators: Ireland’s Media Commission (“Coimisiún na Meán”) for ChatGPT, and the Authority for Consumers and Markets (“Autoriteit Consument & Markt”) in the Netherlands for Reddit and Roblox.

The European Commission stated that it has now designated 28 VLOPs and VLOSEs under the DSA. That figure reflects the EU’s ongoing effort to subject the largest digital services to enhanced oversight where their scale may create outsized risks for users, public discourse, and core societal interests.

Read the European Commission’s press release.