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DSA Puts ChatGPT, Reddit and Roblox Under Stricter EU Scrutiny
159.1 million average monthly users in the European Union. That is the number of ChatGPT users, according to OpenAI, which pushes it onto the list of tools monitored under the DSA (Digital Services Act). On August 31, 2026, the European Commission designated the chatbot as a very large online search engine, and added Reddit and Roblox as online platforms. Here is what this changes in practice.
A chatbot reclassified as a search engine
The DSA threshold is already well known: 45 million average monthly users in the EU. Three services have crossed this threshold and are now included in the official DSA register: ChatGPT, Reddit and Roblox. Here is what the numbers show:
- ChatGPT (OpenAI): 159.1 million average monthly active users in the EU.
- Reddit: 57.2 million.
- Roblox: 46.6 million, just 1.6 million above the threshold.
ChatGPT's classification is the real novelty. The Commission did not place it in the platform category, but in that of very large online search engines. To explain this choice, the European Commission says that ChatGPT is an AI system capable of interacting with users and answering their queries, including by performing web searches. Brussels concludes that it is a hybrid service that falls under the search engine category within the meaning of the DSA. Reddit and Roblox, meanwhile, fall into the online platform category because they allow third-party content to be disseminated to the public.
By comparison, Facebook and Instagram have 259 million average monthly active users in the EU, while TikTok stands at 135.9 million: ChatGPT is therefore above this social network.
Four months to comply
From the time of notification, the three services have four months to apply the additional obligations reserved for them. That means until the end of 2026. Otherwise, as usual, fines will be imposed.
As for the obligations, they are built around assessing and mitigating several types of risks:
- The dissemination of illegal content.
- Negative effects on minors.
- The physical and mental well-being of users.
- Fundamental rights.
- Electoral processes and public security.
These are in addition to the other DSA requirements for this category, including annual independent audits, transparency around recommendation systems, and researcher access to data. In the event of non-compliance, the penalty can take the form of a fine of up to 6% of annual global revenue. And there are already examples we can point to. Indeed, the European Commission has already fined X €120 million in December 2025, Temu €200 million in May 2026 and AliExpress €550 million in July 2026 (notably because of illegal products). In addition, 8 investigations are ongoing (Shein, Snapchat, etc.), so it is not out of the question that more fines could follow...
Henna Virkkunen, Executive Vice-President for Tech Sovereignty, Security and Democracy, said: "These new designations mean that ChatGPT, Reddit and Roblox will now be subject to a higher level of scrutiny and accountability in the European Union, commensurate with their significant impact on our citizens and society. We continue to monitor the digital landscape closely and will not hesitate to designate any platform that reaches the required threshold for enhanced scrutiny under the Digital Services Regulation."
With these three additions, the European Commission now oversees 28 very large platforms and very large search engines under the DSA (full list here). Read the official press release on this page.
