EU DSA triggers VLOP designation for ChatGPT, Reddit, and Roblox - what AI builders should know

The European Commission designated OpenAI's ChatGPT as a Very Large Online Search Engine (VLOSE), and Reddit and Roblox as Very Large Online Platforms (VLOPs) under the Digital Services Act (DSA). The designation triggers the EU's strictest regulatory tier for any service that surpasses 45 million monthly users in the bloc Independent.ie. For AI builders, this means stricter content moderation, transparency reporting, and risk mitigation requirements are now a material compliance factor for any product reaching EU users.

The new obligations for VLOPs and VLOSEs

VLOPs and VLOSEs must file transparency reports, detail risk mitigation plans, and pay an annual fee to the EU. The DSA requires these platforms to clamp down on illegal and harmful content. For ChatGPT, this is a first for an AI chatbot being classified as a search engine The Verge. Reddit and Roblox now join the same category as Meta's Facebook, Instagram, and Elon Musk's X.

Roblox has already tightened child-safety controls and is expanding advertising, which the DSA aims to make more transparent when marketing to minors Independent.ie.

Up to 6% of global annual sales at risk

Breaches of the DSA carry penalties of up to 6% of a company's annual global sales. The European Commission has opened more than a dozen probes into online platforms since the DSA came into force in 2022, signaling active enforcement Independent.ie.

What this means for AI builders and platform operators

If you are building AI products, social platforms, or user-generated content services that attract EU users, the 45 million threshold is a concrete regulatory trigger. Even below that threshold, the DSA's obligations for smaller platforms still apply but are less onerous. For AI builders, the key takeaways are:

• Transparency reporting: You need to document how your AI system works, what content moderation measures are in place, and how you handle harmful content.
• Risk mitigation: You must conduct risk assessments and implement measures to address systemic risks, including the spread of illegal content and negative impacts on minors.
• Annual fees: The fee structure is based on user numbers, so scaling to 45 million EU users adds a significant compliance cost.
• Child safety: Services used by minors face enhanced scrutiny on advertising and content moderation practices.

Caveats and what remains unclear

The exact fee structure, specific deadlines for compliance, and detailed obligations for VLOSEs like ChatGPT are still evolving. The source material combines regulatory details with broader context about US-EU tensions, and some specifics should be cross-checked against official EU DSA texts. The designation also reflects ongoing friction with US authorities, who have criticized the DSA for targeting American firms Independent.ie.

For now, AI builders should treat this as a clear signal that EU regulatory risk for AI platforms is increasing, and that the DSA is the primary framework to prepare for.