European Commission Designates ChatGPT, Reddit, and Roblox as 'Very Large,' Tightening Regulation

On August 31, the European Commission announced that, pursuant to the Digital Services Act (DSA), it has officially designated ChatGPT, Reddit, and Roblox as subjects of regulation.

The European Commission stated that the aforementioned services have reached over 45 million average monthly active users within the EU, meeting the statutory threshold for designation. It classified ChatGPT as a Very Large Online Search Engine, and designated Reddit and Roblox as Very Large Online Platforms.

Note: Under the Digital Services Act, once entities are included in the list of Very Large Online Platforms or Very Large Online Search Engines, the relevant companies must comply with a series of stricter rules and obligations established by the EU, including risk assessments, content moderation, transparency reporting, and other regulatory requirements.

The European Commission explained that ChatGPT is an artificial intelligence system capable of interacting with users and responding to their prompts and queries (including performing web searches). Therefore, ChatGPT is considered a hybrid service that constitutes an online search engine under the DSA framework.

Following the designation notification, the relevant platforms have a four-month transition period (i.e., until the end of December 2026) to meet the additional compliance requirements established by the DSA for Very Large Online Platforms and Very Large Online Search Engines.

Previously, Roblox, Reddit, and ChatGPT were already subject to the general statutory obligations prescribed by the DSA for standard online platforms and search engines.