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

On August 31, 2026, the European Commission designated OpenAI's ChatGPT as a Very Large Online Search Engine, alongside Reddit and Roblox as Very Large Online Platforms under the Digital Services Act. All three surpassed the 45 million EU user threshold, with ChatGPT reaching 159.1 million. They have until late December 2026 to implement systemic risk audits covering illegal content and child safety, or face fines of up to 6% of global turnover.

ChatGPT search engine classification

• ▪Before ChatGPT's designation, Google Search and Microsoft's Bing were the only search engines classified as Very Large Online Search Engines under the Digital Services Act.
• ▪The European Commission classified ChatGPT as a search engine because its web-search feature allows it to respond to user prompts and perform live web searches.

User threshold requirements

• ▪The Digital Services Act's threshold for a "very large" designation is an average of 45 million monthly active users in the European Union.
• ▪OpenAI reported that ChatGPT averaged approximately 159.1 million monthly active users in the European Union for the six-month period ending March 31, 2026.
• ▪Reddit reported having approximately 57.2 million monthly active users in the European Union, while Roblox reported having between 46.6 million and 48 million users.

Compliance deadline December 2026

• ▪The European Commission will supervise compliance in cooperation with Ireland's Coimisiún na Meán for ChatGPT and Reddit, and the Netherlands' Authority for Consumers and Markets for Roblox.
• ▪OpenAI, Reddit, and Roblox have a four-month compliance window following their August 31, 2026 designation, establishing a deadline at the end of December 2026.

Risk assessment obligations

• ▪Designated services must conduct annual systemic risk assessments evaluating how their platforms amplify illegal content, harm minors, affect mental health, and impact elections.
• ▪Designated platforms are required to submit to independent third-party audits, share data with vetted researchers, and establish reporting mechanisms for illegal content.

Revenue-based penalty structure

• ▪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 daily turnover.
• ▪Non-compliance with the Digital Services Act can result in financial penalties of up to 6% of a company's global annual turnover.