The EU Just Designated ChatGPT, Reddit, and Roblox as Very Large Platforms. Here Is What That Means.

The European Commission has designated ChatGPT as a Very Large Online Search Engine and Reddit and Roblox as Very Large Online Platforms under the Digital Services Act. All three services declared at least 45 million average monthly users in the European Union, crossing the threshold that triggers a higher tier of regulatory obligations under the DSA.

They now have four months to comply, with a deadline of January 2027.

What the designation requires

Being designated as a Very Large Online Platform or Search Engine under the DSA is not a symbolic status. It comes with a specific set of obligations that go beyond what the DSA requires of smaller platforms.

The central requirement is a systemic risk assessment. Each platform must identify and mitigate risks stemming from its services and algorithmic systems across several categories: the dissemination of illegal content, negative effects on minors, impacts on users' physical and mental wellbeing, fundamental rights, electoral processes, and public security.

These assessments are not self-reported and filed away. They are subject to oversight by the European Commission and the relevant national supervisory authorities. Platforms that fail to comply face significant financial penalties under the DSA's enforcement framework.

ChatGPT: a new category entirely

ChatGPT's designation stands apart from the other two. The Commission classified it not as a platform but as a Very Large Online Search Engine, because ChatGPT can search the web in response to user queries, making it a hybrid service that qualifies as an online search engine under the DSA's definitions.

It is the first AI system to receive this designation. That matters because search engines carry specific obligations under the DSA around transparency of ranking systems and access to data for researchers. Those obligations were written with traditional search engines in mind. Applying them to a conversational AI system will require regulators and the platform to work through questions that have no established precedent yet.

Reddit and Roblox

Reddit and Roblox are designated as Very Large Online Platforms because they enable users to share third-party content with the public, which is the defining characteristic of a platform under the DSA.

Reddit is a discussion platform built around topic-based communities where users create, share, and interact with content. Roblox is a gaming and creation platform where users publish and play games built by other users. Both were already subject to the DSA's general platform obligations before this designation. What changes now is the addition of the systemic risk assessment requirements, along with the closer oversight that comes with VLOP status.

For Roblox in particular, the obligation to assess negative effects on minors is likely to be a significant focus. The platform's user base skews young, and the DSA's provisions around the protection of minors are among its most detailed and prescriptive.

Who oversees compliance

Supervision is split between the European Commission and national authorities, depending on where each platform has its EU headquarters.

Ireland's Coimisiún na Meán will oversee ChatGPT and Reddit, both of which are headquartered in Ireland for EU purposes. The Netherlands' Authority for Consumers and Markets will supervise Roblox, whose EU headquarters are in the Netherlands.

This matters because national supervisory authorities bring different enforcement cultures, resources, and priorities. Coimisiún na Meán has already opened formal investigations into Meta's platforms over dark patterns and recommender system design.

What comes next

The January 2027 deadline gives each platform four months from the date of designation to demonstrate compliance. Four months is a short window, given that the assessments involved require internal audits and in some cases changes to how algorithmic systems are documented.

For organisations building on or integrating with these platforms, the designations are also relevant. The systemic risk assessments these platforms must conduct will put scrutiny on how their recommendation systems, notification mechanics, and content moderation practices affect users, particularly minors and vulnerable groups.

Fairpatterns detects and documents these design patterns at scale, across platforms and jurisdictions.