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Privacy & Cybersecurity Law Blog

FTC Rescinds 2021 Policy Statement on Health App Data Breaches EU Cyber Resilience Act Reporting Obligations Take Effect for Manufacturers Delaware Expands State Privacy Law Dutch DPA Fines Uber Over Automated Decisions Affecting Drivers China Issues New Rules on Cyberspace Security Inspection Court Approves Meta Settlement With 29 States Over Alleged Harms to Children and Teens FTC Proposes Enforcement Policy Statement on Personalized Pricing New Jersey Enacts the Kids Code Act with Privacy-by-Default and Safety-by-Design Obligations White House Memorandum Establishes Framework for Government-Directed Private-Sector Cyber Operations FTC, California and Utah Sue Telehealth Company Hims & Hers for Deceptive and Unlawful Privacy Practices CalPrivacy Settles with Two Data Brokers over Registration Failures and Privacy Violations New York Attorney General Releases Final Rules for SAFE for Kids Act EDPB Adopts Guidelines on Anonymous Data, Web Scraping, and Blockchain China Publishes Official Q&A on Administrative Policies for Cross-Border Data Transfers Hawaii Enacts AI Companion Disclosure and Safety Law EDPB Calls for Review of EU-U.S. Data Privacy Framework After U.S. Supreme Court Decision on FTC Independence CNIL Issues FAQs on Recommendation for Tracking Pixels in Emails European Commission Issues Guidance on the Cyber Resilience Act European Commission Issues EU AI Act Transparency Guidelines EU Digital Omnibus on AI Enters Into Force Connecticut AG Leads Multistate Settlement With 23andMe Over 2023 Data Breach CalPrivacy Targets Gig Economy Tech Platforms in First CCPA Compliance Audit New Jersey Adopts New Data Broker Registration Regime and Sensitive Data Sale and Licensing Restrictions CISA Plans to Finalize Cyber Incident Reporting Regulations in September 2026 Illinois Governor Signs Frontier AI Model Law New Hampshire Amends the NHDPA to Prohibit the Sale of Children’s Personal Data Canada’s Proposed Social Media Ban for Children and Chatbot Regulation: Bill C-34’s Impact on Platforms European Commission Unveils Cybersecurity and AI Action Plan European Commission Refers Four Member States to CJEU Over NIS2 Transposition Delays EDPB Opens Public Consultation on New Personal Data Breach Notification Template
European Commission Designates ChatGPT, Reddit, and Roblo...
2026-09-04 · via Privacy & Cybersecurity Law Blog

European Commission Designates ChatGPT, Reddit, and Roblox Under the Digital Services Act

On August 31, 2026, the European Commission announced that it had designated ChatGPT as a Very Large Online Search Engine (“VLOSE”) and Reddit and Roblox as Very Large Online Platforms (“VLOPs”) under the Digital Services Act (“DSA”). The DSA classifies platforms or search engines with more than 45 million average monthly users in the European Union as VLOPs or VLOSEs, respectively. According to the European Commission, each of the three services met the relevant threshold.

The DSA imposes a stricter compliance regime on VLOPs and VLOSEs than on other online platforms and search engines. In general terms, a VLOP is an online platform with a very large EU user base that disseminates information or content to the public, while a VLOSE is a search engine with a comparably large reach in the EU. These categories are intended to capture services whose scale gives them a heightened capacity to shape public discourse, influence user behaviour, and amplify systemic risks across the EU internal market. Once a service is designated as a VLOP or VLOSE, it becomes subject to additional obligations beyond the DSA’s baseline rules.

The European Commission stated that ChatGPT qualifies as a hybrid service that falls within the DSA’s VLOSE category because it can search the web in response to user prompts. Reddit and Roblox were designated as VLOPs because they enable users to disseminate third-party content to the public. Reddit does so through user posts and discussions, while Roblox allows users to create, publish, and play games developed by other users.

Following designation, ChatGPT, Reddit, and Roblox have four months, until January 2027, to comply with the additional DSA requirements for very large services. Those obligations include assessing and mitigating systemic risks related to illegal content, adverse effects on minors, users’ physical and mental well-being, fundamental rights, electoral processes, and public security. Previously, the three services were already subject to the DSA’s general rules.

The designation also gives the European Commission supervisory and investigative authority over these services under the DSA. The Commission will oversee compliance in cooperation with the relevant national Digital Services Coordinators: Ireland’s Media Commission (“Coimisiún na Meán”) for ChatGPT, and the Authority for Consumers and Markets (“Autoriteit Consument & Markt”) in the Netherlands for Reddit and Roblox.

The European Commission stated that it has now designated 28 VLOPs and VLOSEs under the DSA. That figure reflects the EU’s ongoing effort to subject the largest digital services to enhanced oversight where their scale may create outsized risks for users, public discourse, and core societal interests.

Read the European Commission’s press release.