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Guides ChatGPT, Reddit and Roblox land in the DSA's strictest supervision tier Published Aug 31, 2026 On August 31, 2026, the European Commission designated ChatGPT as a Very Large Online Search Engine (VLOSE) and Reddit and Roblox as Very Large Online Platforms (VLOP) under the Digital Services Act. All three declared at least 45 million average monthly EU users, the threshold that triggers the DSA’s strictest supervision tier. They now have four months from notification - into January 2027 - to comply with the full obligation set, with fines up to 6 percent of global annual turnover behind it. View this post on X → Henna Virkkunen, the Commission’s Executive Vice-President for Tech Sovereignty, Security and Democracy: “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. We continue to watch the digital landscape closely and will not hesitate to designate any platform that meets the threshold for enhanced supervision under the Digital Services Act.” The numbers that triggered it The DSA’s VLOP/VLOSE threshold is 45 million average monthly EU users. Each service declares its own figure in its six-monthly reports: Service Declared EU users Category ChatGPT 159.1 million VLOSE Reddit 57.2 million (July) VLOP Roblox 46.6 million (July) VLOP ChatGPT clears the line more than three times over; Roblox crossed at 46.6 million. The three designations bring the running total of designated VLOPs and VLOSEs to 28 services. Self-declared average monthly EU users per service against the 45 million DSA designation threshold, per the Commission’s August 31, 2026 announcement and the services’ declarations. What designation obligates The additional DSA obligations that now apply: Assess and mitigate systemic risks spanning illegal content, negative effects on minors, effects on users’ physical and mental well-being, fundamental rights, electoral processes, and public security. Undergo independent annual audits and maintain internal compliance functions. Provide vetted researchers with access to data. Offer users a recommender option that is not based on profiling. Compliance is due four months from notification. The penalty ceiling is 6 percent of global annual turnover, and the Commission can add periodic penalties of up to 5 percent of average daily turnover for continued breach. The classification call ChatGPT is the first AI chatbot in this tier, and the Commission had a choice to make: platform or search engine. It picked the search-engine category - VLOSE - which puts ChatGPT’s search product in the same regulatory bucket as web search. The obligations are close to identical across the two categories. The enforcement record so far The DSA’s first three penalties, all under the 6 percent ceiling: X, fined 120 million euros on December 5, 2025 - the first DSA penalty - over blue-check deception, ads-repository gaps, and blocked researcher access. Temu, fined 200 million euros on May 28, 2026 over systemic-risk failures in illegal-product handling (failed chargers, unsafe toys in mystery-shopping tests). AliExpress, fined 550 million euros on July 20, 2026 - the largest to date - for failing to assess and mitigate illegal and counterfeit product risks; it is appealing and has called the fine “disproportionate.” The three DSA fines to date: X at 120 million euros, Temu at 200 million, AliExpress at 550 million - all under the 6 percent-of-turnover ceiling the newly designated services now face. What it means for self-hosters The DSA designates services, not model weights. OpenAI’s 159.1 million EU users are what crossed the threshold; a model is not a service until someone operates it at scale. ChatGPT can now be fined up to 6 percent of global turnover, and its EU users get non-profiling recommendation options, researcher data access, and minor-protection measures that apply to the hosted product they use. A model run on your own hardware has no operator the Commission can designate. The DSA attaches obligations to whoever serves users at scale - a self-hosted deployment has none. The four-month clock puts the first compliance deadline in January 2027, when the first systemic-risk assessments under these designations are due.