EU Designates ChatGPT, Reddit, and Roblox Under Digital Services Act After 45M Users

The European Commission has designated ChatGPT, Reddit, and Roblox under the EU Digital Services Act (DSA) after each platform crossed 45 million average monthly users in the European Union. This means OpenAI's chatbot, Reddit, and Roblox must now assess and mitigate risks related to illegal content, protection of minors, and users' mental health. For AI builders, this signals that AI-enabled services are no longer outside the scope of platform regulation, and compliance work is becoming a practical requirement for any service reaching EU scale.

The 45M User Threshold Triggered DSA Oversight

The DSA, which came into effect across the bloc in February, applies to platforms that serve over 45 million average monthly users in the EU. Once a platform crosses that line, it must comply with stricter rules on transparency, risk management, and accountability. The European Commission said on Monday that ChatGPT, Reddit, and Roblox have now passed that threshold, making them subject to the DSA's most stringent obligations. Reddit and Roblox are classified as Very Large Online Platforms (VLOPs), while ChatGPT is designated as a Very Large Online Search Engine, a category that reflects how the EU views its search-like functionality.

ChatGPT Becomes the First AI Chatbot Under the DSA

ChatGPT is the first AI chatbot to fall under the DSA's jurisdiction. This is a notable shift: the DSA was originally designed for social media, marketplaces, and search engines, but the EU has now extended its reach to generative AI services that operate at scale. OpenAI's ChatGPT is also subject to separate European AI regulations under the EU AI Act, meaning it now faces overlapping compliance requirements. For builders deploying AI chatbots or agentic services in Europe, this dual regulatory layer is a preview of what may come for other AI products that reach similar user counts.

What the DSA Obligations Mean for Builders

The DSA requires designated platforms to conduct annual risk assessments and implement mitigation measures for systemic risks. For ChatGPT, this includes evaluating how its model might generate illegal content, how it affects minors, and what impact it has on users' mental health. For Reddit and Roblox, the focus is on content moderation, user safety, and platform design. These obligations are not optional: the European Commission can impose fines of up to 6% of global annual turnover for non-compliance. Builders operating AI services in the EU should watch how OpenAI implements these requirements, as the approach may set a precedent for other AI platforms.

Compliance Timelines and What Remains Unclear

The DSA gives designated platforms a period to comply, with some reporting suggesting a timeline extending to December 2026 for certain provisions. However, the exact deadlines and specific requirements for ChatGPT as an AI service are still being clarified. The source evidence for this story is based on initial reporting and may not capture every regulatory nuance. What is clear is that the EU is actively expanding its oversight of large digital services, and AI builders should expect more designations as user bases grow. If your product serves over 45 million EU users, or is on track to do so, now is the time to start mapping DSA compliance requirements.