EU designates ChatGPT, Reddit and Roblox under strictest Digital Services Act rules

On August 31, 2026, the European Commission designated OpenAI's ChatGPT, Reddit, and Roblox under its strictest Digital Services Act rules after they surpassed the 45 million monthly active user threshold in the European Union. ChatGPT is classified as a search engine, while Reddit and Roblox are designated as online platforms. The companies have four months to comply with strict risk mitigation and audit requirements or face fines of up to 6% of their global annual turnover.

DSA very large platform designation

• ▪Joost Hagesteijn, Roblox's general manager for Europe, expressed pride in Roblox becoming the first gaming platform to reach the Digital Services Act milestone in the European Union.
• ▪The European Commission's designation of ChatGPT, Reddit, and Roblox on August 31, 2026, brings the total number of platforms and search engines under the Digital Services Act's strictest tier to 28.
• ▪On August 31, 2026, the European Commission designated OpenAI's ChatGPT, Reddit, and Roblox under the strictest Digital Services Act rules.
• ▪The European Commission will supervise compliance with the Digital Services Act in cooperation with Ireland's Coimisiún na Meán for ChatGPT and Reddit, and the Netherlands' Authority for Consumers and Markets for Roblox.

ChatGPT search engine classification

• ▪Under the Digital Services Act, the European Commission classified OpenAI's ChatGPT as a Very Large Online Search Engine because it can search the web and respond to user queries.
• ▪The European Commission classified Reddit and Roblox as Very Large Online Platforms because they enable users to create and share third-party content publicly.

Systemic risk assessment requirements

• ▪Designated platforms under the Digital Services Act must submit to independent yearly audits, open their data to vetted researchers, and offer a version of their recommender systems that does not profile users.
• ▪OpenAI, Reddit, and Roblox have four months following their August 31, 2026 designation to comply with additional Digital Services Act obligations.
• ▪Under the Digital Services Act, designated platforms must assess and mitigate systemic risks including illegal content dissemination, harm to minors, and negative impacts on users' physical and mental wellbeing.

EU enforcement penalties

• ▪Continued breach of a European Commission order under the Digital Services Act can draw daily fines of up to 5% of a company's global turnover.
• ▪Non-compliance with the Digital Services Act can result in financial penalties of up to 6% of a company's global annual turnover.
• ▪The European Commission's Digital Services Act enforcement has previously produced fines including €550 million against AliExpress, €200 million against Temu, and €120 million against X.

Monthly user thresholds

• ▪Reddit reported 57.2 million monthly active users in the European Union, while Roblox reported between 46.6 million and 48 million monthly active users.
• ▪OpenAI reported that ChatGPT's search function averaged approximately 159 million monthly active users in the European Union for the six months ending March 2026.
• ▪Under the Digital Services Act, online services are classified as very large if they reach an average of at least 45 million monthly active users in the European Union.