159 million monthly users: ChatGPT was classified as a search engine, not a chatbot—a regulatory label with real teeth. Four months to comply. Fines up to 6% of global revenue if they don’t.
The European Commission designated ChatGPT, Reddit, and Roblox under the Digital Services Act‘s strictest tier Monday, subjecting all three to the bloc’s toughest online safety regime. ChatGPT is a Very Large Online Search Engine (VLOSE); Reddit and Roblox join as Very Large Online Platforms (VLOPs). The threshold for either designation is 45 million average monthly EU users — OpenAI reported ChatGPT’s search function averaged 159 million monthly active users in the bloc over the six months ending March 2026. Reddit reported 57.2 million; Roblox 48 million. All three have until the end of November to comply, bringing the total number of platforms under the DSA’s strictest tier to 28.
What’s Happening & Why It Matters
Why ChatGPT Got Classified as a Search Engine
The most consequential detail is the specific category ChatGPT falls in. The Commission concluded that an AI chatbot pulling live results from the internet functions, in regulatory terms, as a search engine — not a conversational platform. That’s a meaningful legal distinction, and one OpenAI didn’t choose. It’s the first time any AI chatbot has been designated under the DSA, and the Commission chose to treat ChatGPT’s real-time web-search capability as the defining feature that triggers the toughest oversight category, rather than classifying it as a more regulated online platform.
Henna Virkkunen, the Commission’s executive vice-president for tech sovereignty, bound the designations by scale and impact: “These new designations mean that ChatGPT, Reddit and Roblox will be held to a higher standard of scrutiny and accountability in the European Union, in line with their large impact on our citizens and society.” She added a specific warning beyond the three companies — the Commission “will not hesitate to designate any platform” that clears the 45 million threshold.
What Compliance Requires
The obligations attached to VLOP and VLOSE status are substantial, not symbolic. All three companies must complete annual systemic risk assessments covering illegal content, protection of minors, effects on users’ mental and physical wellbeing, fundamental rights, electoral processes, and public security. They must submit to independent audits and share data with regulators and vetted researchers—a transparency requirement that goes beyond most platforms’ existing voluntary disclosure practices.
Enforcement supervision splits by company. The Commission works with Ireland’s Coimisiún na Meán as the digital services coordinator for ChatGPT and Reddit, and the Netherlands’ Authority for Consumers and Markets (ACM) for Roblox. That dual-regulator structure is where each company’s EU operations are headquartered, giving national authorities oversight alongside Brussels’ supervisory role. Failure to meet the December deadline risks fines of up to 6% of global revenue — the same penalty ceiling TF has documented across multiple DSA enforcement actions throughout 2026.
A Pattern Building Since Late 2025
The designation didn’t come without warning. As early as October 2025, reporting suggested ChatGPT could face classification after surpassing 120 million EU monthly users — a threshold the Commission was already signalling it would take well before Monday’s formal announcement. The gap between that signal and the designation is the DSA’s own procedural pace: the Commission monitors user numbers, confirms them against company disclosures, then acts once the threshold is clearly, consistently met.
So what comes next? Roblox’s designation carries particular weight given the platform’s young user base — TF reported how EU regulators have prioritised child safety obligations across every major tech enforcement action in 2026, from age-verification rules to AI content labelling. A platform built around user-generated games, with tens of millions of minors among its EU user base, faces the same systemic risk assessment requirements as Meta and TikTok.
TF Summary: What’s Next
ChatGPT, Reddit, and Roblox have until the end of November to comply with the full suite of VLOP and VLOSE obligations. The Commission’s oversight through Ireland’s Coimisiún na Meán and the Netherlands’ ACM begins alongside the four-month compliance window. No specific enforcement action has been announced yet, given the designations only took effect Monday. Additional platforms crossing the 45 million EU user threshold are subject to future designation under the same process.
MY FORECAST: Expect ChatGPT’s compliance to prove more complex than Reddit’s or Roblox’s, given the search-engine classification requires OpenAI to build systemic risk assessment infrastructure for a product category — AI-powered search — that didn’t exist when the DSA’s own compliance framework was designed. Watch for OpenAI to fight back on aspects of the search-engine categorisation, even while complying with the obligations, given how that label shapes public and regulatory perception of what ChatGPT is. Roblox faces the sharpest child-safety scrutiny of the three and is expected to draw the most public attention when its systemic risk assessment is published, given the platform’s young user demographic and the EU’s consistent 2026 pattern of prioritising minor protection above every other DSA enforcement category.
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