The European Commission issued a fresh round of designations under the Digital Services Act (DSA) on August 31: ChatGPT was classified as a Very Large Online Search Engine (VLOSE), while Reddit and Roblox were designated Very Large Online Platforms (VLOPs). It's the first time an AI chatbot has been placed in the framework's top tier.
The trigger is user scale. The DSA sets the bar at more than 45 million average monthly active users within the EU — roughly a tenth of the bloc's population. All three cleared it comfortably: ChatGPT reported 159 million monthly EU users, Reddit 57.2 million, and Roblox 48 million. With these three added, 28 services now fall under the DSA's strictest tier of rules.
Why “search engine”
The reasoning is spelled out in the Commission's own language: ChatGPT is an AI system that interacts with users and responds to their prompts and queries, including by performing web searches — and under the DSA's definition, that capability alone is enough to qualify as an online search engine.
The distinction matters in practice. The DSA splits very-large services into two tracks — VLOPs, for platforms that host user-generated content, and VLOSEs, for search services that retrieve and present third-party information — and the compliance obligations for each don't fully overlap. Reddit and Roblox fall under the VLOP track, which means dealing with content their own users post. ChatGPT falls under VLOSE, which means dealing with what it retrieves, organizes, and paraphrases back to users. For a model that searches and answers in the same breath, the boundary of that second kind of responsibility is far blurrier than the first.
Oversight has already been assigned. ChatGPT and Reddit will answer to Ireland's Digital Services Coordinator, while Roblox goes to the Dutch Authority for Consumers and Markets.
Four months of homework
All three companies get a four-month transition period, after which they must meet roughly three obligations: conduct an annual systemic risk assessment, submit to an independent audit, and share data with regulators and vetted researchers.
The risk-assessment scope is written broadly — illegal content, protection of minors, users' physical and mental well-being, and fundamental rights. For Reddit and Roblox, those categories point to content moderation and teen-safety fights that have already been running for years. For ChatGPT, the object of assessment shifts to the model's own output: under what circumstances it might give harmful advice, how tightly its responses to minors should be constrained, and how to quantify the reliability of the sources it retrieves. The DSA framework doesn't yet have a mature audit methodology for any of that. The first round of audit reports will be the industry's first public sample.
The data-sharing requirement carries similar weight. Vetted researchers get access to platform data for research purposes — a mechanism that has run for two years on social platforms but is being applied to a closed-source model product for the first time. Whether researchers will get usage-side statistics or records that actually touch model behavior hasn't been specified yet.
Penalties remain at the DSA's standard level: violations can draw fines of up to 6% of global annual revenue.
A reference line
European Commission Executive Vice-President Henna Virkkunen said in a statement that the new designations mean ChatGPT, Reddit and Roblox will now be held to a higher standard of scrutiny and accountability: “These new designations mean that ChatGPT, Reddit and Roblox will now be held to a higher standard of scrutiny and accountability.” The Commission added that it will keep monitoring the digital landscape closely and won't hesitate to act on any platform that crosses the threshold.
Set against the EU's roughly 450 million population, 159 million works out to close to a third. ChatGPT's penetration in Europe is already on the same order of magnitude as mainstream social products, so being pulled into the strictest tier was only a matter of time. The designation that will really matter going forward applies to the ones still waiting in line: products like Gemini, Copilot, and Perplexity that also carry search capability. Any future conversation about EU compliance for them will have to start by measuring their own user numbers against the VLOSE line.
Sources: European Commission DSA designation announcement, Euronews, CocoLoop, ITHome; the EU monthly-user figures and the 45-million threshold follow the Commission's announcement, and both reports agree on the length of the transition period.