The European Commission has designated ChatGPT (a generative AI chatbot developed by OpenAI) as a Very Large Online Search Engine (VLOSE), alongside Reddit (online social media platform and discussion network) and Roblox (an online gaming platform) as Very Large Online Platforms (VLOPs), under the Digital Services Act (DSA). The designations follow confirmations from all three services that they reach at least 45 million average monthly active users in the European Union, meeting the statutory threshold for designation.
Under the DSA, ChatGPT is classified as a hybrid service qualifying as a search engine due to its ability to engage with user prompts and search the web, while Reddit and Roblox qualify as online platforms because they allow users to share and interact with third-party content. While these services were already subject to general DSA rules, their new designations trigger additional, stricter obligations.
By January 2027, the companies must assess and mitigate systemic risks connected to their services and algorithms. This includes addressing the dissemination of illegal content, potential negative effects on minors, impacts on physical and mental well-being, fundamental rights, electoral processes, and public security.
The designation gives the Commission investigative powers to evaluate the internal functionalities and systems of these services. The Commission will supervise compliance directly, working in cooperation with national Digital Services Coordinators where the platforms are established: Coimisiún na Meán in Ireland for ChatGPT, and the Authority for Consumers and Markets in the Netherlands for Reddit and Roblox. This brings the total number of designated very large online platforms and search engines under the DSA to 28.
