The European Commission has formally designated ChatGPT, Reddit and Roblox under the Digital Services Act, the EU's strictest regime for online platforms, according to The Verge. ChatGPT enters the framework as a Very Large Online Search Engine (VLOSE), while Reddit and Roblox are designated Very Large Online Platforms (VLOPs) — a move that subjects OpenAI to binding European obligations on content moderation, minors' safety and algorithmic transparency for the first time.

The designations, announced on Monday, mean OpenAI will soon be held accountable for mitigating risks related to ChatGPT's impact on minors, user mental health, and the spread of illegal content across the European Union. For more context on this story, see our ongoing AI industry coverage.

Why the EU Considered ChatGPT a Search Engine

Under the DSA, online platforms and search engines are considered "Very Large" once they reach at least 45 million average monthly users in the EU — roughly one in ten of the bloc's population, as Euronews noted. Whether ChatGPT counted as a platform or a search engine had been a point of curiosity among regulators and commentators alike; the Commission settled on the search engine classification, a decision that Gizmodo flagged as the EU officially deciding ChatGPT is a search engine.

Reddit and Roblox, by contrast, were designated as Very Large Online Platforms because both allow users to create and share content publicly, placing them in the same category as established social networks.

What the Obligations Mean for OpenAI, Reddit and Roblox

The DSA imposes a defined set of duties on designated services:

  • Risk mitigation: companies must assess and reduce systemic risks tied to minors' safety, user mental health, and the spread of illegal content.
  • Advertising limits: platforms may not target ads at minors, and cannot personalize advertising using sensitive attributes such as sexual orientation, religion, ethnicity or political beliefs.
  • Algorithmic transparency: services must explain how their recommendation algorithms work and offer users options that are not based on profiling.

For OpenAI specifically, the search engine designation brings ChatGPT under supervision the company has not previously faced in Europe. The Verge reported that ChatGPT, Reddit and Roblox have until the end of December 2026 to comply with the rules.

Brussels Points to Its Enforcement Record

EU executive vice-president for tech sovereignty, security and democracy Henna Virkkunen said in the announcement: "These new designations mean that ChatGPT, Reddit and Roblox will now 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."

Brussels has backed the framework with substantial penalties. According to Euronews, the DSA has already produced around 870 million euros in fines, including a record 550-million-euro penalty against AliExpress in July for failing to curb illegal and counterfeit goods, a 200-million-euro fine against Temu in May, and a 120-million-euro fine against X in December 2025 over content moderation and transparency failures. Non-compliance can cost a company up to 6 percent of its global annual turnover — a figure that could prove substantial for OpenAI given its rapid revenue growth.

A New Flashpoint in EU-US Tech Tensions

The designations land amid already strained transatlantic relations over digital regulation. The Trump administration has previously described EU digital fines on American technology companies as a form of economic extortion and threatened retaliation against countries with digital rules targeting US firms. Bringing three more American-owned services under direct Commission supervision is likely to sharpen that rhetoric.

For its part, OpenAI has generally positioned itself as willing to work with European regulators, and the company already complies with the EU's AI Act transparency provisions for general-purpose models. But the DSA's content-moderation machinery — audits, risk assessments and data access for regulators — is an operationally different burden than model documentation.

Stacking on Top of the AI Act

The designation also means ChatGPT now sits under two overlapping European regimes at once. The EU's AI Act, whose enforcement powers and penalty framework for general-purpose AI models took effect on August 2, already requires OpenAI to meet transparency obligations for ChatGPT's underlying models. The DSA adds a service-level layer: audits, systemic risk assessments, researcher data access, and advertising restrictions that apply to how the product is operated in the EU, not just how the model was built.

Regulators have framed the two laws as complementary — one governing models, the other governing platforms — but the practical effect is that OpenAI's compliance footprint in Europe is expanding on both fronts within a single year.

What Happens Next

The three companies now enter a compliance runway ending in December 2026. In practice, that means building or expanding teams for systemic risk assessment, ad-targeting restrictions, researcher data access, and transparency reporting tailored to the Commission's expectations.

The move also signals how Brussels intends to treat AI chatbots as they reach mass scale: not as a novel regulatory gray zone, but as mainstream information services subject to the same oversight as search engines and social networks. How OpenAI reconciles that status with a product that generates content rather than indexing it will be one of the more closely watched regulatory questions of the coming year.

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