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ChatGPT, Reddit and Roblox crossed the European Union’s Very Large Online Service threshold, but they did not receive the same legal designation. In a European Commission announcement dated 31 August 2026, ChatGPT was designated a Very Large Online Search Engine (VLOSE), while Reddit and Roblox were designated Very Large Online Platforms (VLOPs) under the Digital Services Act (DSA). The Commission said each service reported at least 45 million average monthly users in the EU.
The practical significance is not an immediate ruling on any individual moderation dispute. It is the start of additional systemic-risk assessment, mitigation and transparency duties. The Commission gave the services four months after notification—stated as running through January 2027—to meet the extra obligations. The formal designation decisions were still listed as unavailable in the Commission register’s 31 August update, so the reasoning and any later compliance findings remain important developments to watch.
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What the European Commission designated
The DSA creates a tiered regulatory system. Rules apply to online services generally, with additional requirements for the largest services because their scale can amplify harms across the EU. The 31 August 2026 announcement added three services to the highest-level group.
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ChatGPT’s designation is as a Very Large Online Search Engine. That legal category is separate from the Very Large Online Platform category, even though both are subject to enhanced DSA duties. Calling all three services VLOPs would therefore be inaccurate. ChatGPT’s classification reflects the Commission’s treatment of the service as a search engine for this designation, while Reddit and Roblox are classified as platforms.
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Reddit and Roblox are VLOPs
Reddit and Roblox were designated Very Large Online Platforms. The VLOP label applies to platforms that meet the DSA’s scale threshold and therefore must address systemic risks associated with how their services operate, distribute content and affect users.
The 45-million-user threshold
The Commission’s announcement says the services declared at least 45 million average monthly users in the EU. The Commission register, updated the same day, records the following provider-reported average monthly active-user figures:
| Service | DSA category | Average monthly active users in the EU | Qualification |
|---|---|---|---|
| ChatGPT | Very Large Online Search Engine (VLOSE) | 159.1 million | Reported by the provider; the register says the figure is without prejudice to the Commission’s assessment of how active recipients were calculated. |
| Very Large Online Platform (VLOP) | 57.2 million | Reported by the provider; subject to the same methodology caveat in the register. | |
| Roblox | Very Large Online Platform (VLOP) | 46.6 million | Reported by the provider; subject to the same methodology caveat in the register. |
These figures are not an independent, like-for-like audience measurement. They are declarations from the providers recorded by the Commission, and the register expressly preserves the Commission’s ability to assess the calculation method. They establish why the services entered the designation process, not a definitive ranking of their audiences.
Why VLOP and VLOSE status matters under the DSA
The DSA’s largest-service obligations are built around systemic effects. A service with tens of millions of EU users can influence access to information, advertising exposure, political discussion, consumer choices and the safety of minors at a scale that ordinary platform rules do not fully address.
Systemic-risk assessments
Designated services must assess risks arising from their services and algorithmic systems and take measures to reduce those risks. The Commission’s announcement identifies several areas for this group:
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- Illegal content and activity.
- Negative effects on minors.
- Users’ physical and mental wellbeing.
- Fundamental rights, including implications for media freedom.
- Elections and democratic processes.
- Public security.
The duty is preventive and ongoing. It requires the providers to examine how design choices, recommender systems, moderation processes and other functions can create or amplify harm, then document and implement mitigation measures. The designation announcement does not state that the Commission has already found ChatGPT, Reddit or Roblox in breach of the DSA.
Algorithmic systems are part of the regulatory focus
Risk analysis is not limited to individual posts or account decisions. It can include the way a service recommends material, ranks results, targets advertising, handles reports, verifies age or designs interfaces. The relevant question is how the whole service may affect rights and public interests when used by a very large EU audience.
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Enhanced transparency and choice
Under the Commission’s DSA overview, platforms must explain the main parameters of recommender systems and how those systems influence what users see. Very large platforms must offer at least one recommendation option that is not based on profiling. Ads must be clearly identified and provide information about who paid for them and why they were shown. Very large platforms must also maintain public ad libraries.
The DSA overview describes additional protections that include a ban on targeted advertising to children, non-personalised feed choices on very large platforms and a ban on deceptive design practices. The exact way a service implements each requirement can depend on its service structure and the detailed legal obligations that apply to its category.
What the designation changes for users
Designation does not create an automatic win in a content dispute, restore every removed account or require a platform to accept every reported item. It does, however, place the service inside a framework with defined information, complaint and redress routes.
Reporting suspected illegal content
Users can report suspected illegal content through the reporting mechanisms a service provides. A report should identify the material, explain why it is allegedly illegal and provide enough information for the service to locate it. The DSA is concerned with illegal content under applicable EU or national law; content that is merely unpopular, inaccurate or offensive may be governed by a service’s own rules rather than an illegality finding.
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When a platform removes content, restricts an account or takes another moderation action, users should receive an explanation of the decision. The explanation is intended to make the action understandable rather than leaving the user with a generic notice that a rule was broken.
Using internal appeals
Users can challenge moderation decisions through a service’s internal complaint system. Keep the original notice, the affected URL or account details, dates and any supporting explanation. Those records help if the internal review does not resolve the issue.
Out-of-court dispute settlement
The DSA provides access to certified out-of-court dispute-settlement bodies for covered disputes. These bodies offer an additional route outside the platform’s own review process. Their existence does not remove the right to pursue judicial remedies under applicable EU or national law.
Complaining to a Digital Services Coordinator
Users who suspect a service is breaching the DSA may complain to the Digital Services Coordinator in their Member State. National coordinators supervise and enforce DSA compliance within their jurisdictions. The European Commission is primarily responsible for monitoring and enforcing the additional obligations that apply to the biggest platforms and search engines.
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1Fix the driver behind crashes, sound loss and screen glitches2Repair Windows errors before they cause bigger problems3Scan for outdated or missing drivers - takes under a minuteWhat ChatGPT’s VLOSE status means in practice
ChatGPT’s classification should be read as a legal category for DSA supervision, not as a statement that every ChatGPT response is treated like a social-media post or that the service has been found unlawful. The VLOSE framework focuses on the systemic effects of a very large search service, including how its algorithms and information presentation may affect rights, public debate, safety and access to lawful information.
Users should therefore watch for clearer explanations of how results or recommendations are generated, how risks are assessed and how complaints are handled. The designation itself does not determine the accuracy of an individual answer, settle a copyright question or decide whether a particular response violates national law.
What Reddit and Roblox’s VLOP status means in practice
For Reddit and Roblox, VLOP obligations apply to platform activity and the systems that shape user participation and content distribution. That can include recommender feeds, advertising, reporting and moderation workflows, protections for minors and safeguards against manipulation or coordinated harmful activity.
The category does not mean that every post, community, game or user is subject to a new EU-wide editorial rule. It means the providers must address systemic risks at service scale and provide the transparency, reporting and redress mechanisms required by the DSA.
The compliance timeline and the facts still unresolved
Four months after notification
The Commission said the services had four months after notification to meet the additional VLOP or VLOSE obligations, specifying the period as running “by January 2027.” That is the operative near-term milestone stated in the 31 August announcement. It should not be treated as proof that every obligation will be fully implemented or independently verified on a particular day without a newer Commission update.
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Formal decisions were not yet available
At the Commission register’s 31 August 2026 update, all three designation entries were marked “decision not yet available; press release.” Until the full decisions appear, readers cannot rely on the register for detailed reasoning, the precise scope of the Commission’s analysis or any service-specific conditions beyond the announcement.
Implementation and enforcement evidence
The key evidence to watch is publication of the formal decisions, the services’ systemic-risk assessments and mitigation measures, and any verified Commission or national enforcement action. A designation is the start of enhanced supervision; it is not itself a finding of non-compliance.
How to interpret the three services side by side
The most useful comparison is legal category, reported EU audience and the same compliance horizon. It is not a comparison of which provider is more compliant, because the available register update does not establish compliance performance.
| Comparison point | ChatGPT | Roblox | |
|---|---|---|---|
| Legal designation | VLOSE | VLOP | VLOP |
| Reported EU average monthly active users | 159.1 million | 57.2 million | 46.6 million |
| Register qualification | Provider-reported; methodology remains subject to Commission assessment | Provider-reported; methodology remains subject to Commission assessment | Provider-reported; methodology remains subject to Commission assessment |
| Near-term milestone | Additional obligations stated as due by January 2027 after notification | Additional obligations stated as due by January 2027 after notification | Additional obligations stated as due by January 2027 after notification |
| Formal decision status in the 31 August 2026 register update | Decision not yet available; press release | Decision not yet available; press release | Decision not yet available; press release |
What users should do if a problem occurs
- Identify the action. Save the notice, date, account name, post or result URL and the rule cited by the service.
- Use the service’s reporting or appeal route. Explain the legal or policy issue clearly and attach relevant evidence.
- Request or review the explanation. Check whether the service identified the specific reason for removal, restriction or suspension.
- Escalate when appropriate. Consider a certified out-of-court dispute-settlement body for an eligible dispute.
- Contact the national Digital Services Coordinator. A complaint can raise suspected DSA non-compliance, but the coordinator’s role is regulatory oversight rather than acting as a personal lawyer in every dispute.
- Preserve judicial options. The DSA does not eliminate judicial redress available under relevant EU or national law.
Why this remains a story to watch
These designations combine unusually large declared EU audiences with a regulatory regime that examines systemic effects rather than isolated moderation incidents. The immediate questions are whether the formal decisions add service-specific reasoning, what risks the providers identify, which mitigations they adopt and how regulators evaluate those steps after the January 2027 compliance period.
For now, the clearest established facts are the legal split—ChatGPT as a VLOSE and Reddit and Roblox as VLOPs—the 45-million-user threshold, the provider-reported figures in the Commission register and the four-month compliance timetable. Later conclusions about effectiveness, breaches or enforcement require newer official decisions or verified implementation evidence.
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