DSA: ChatGPT, Reddit and Roblox are now major search engines and major platforms

On 31 August 2026, the European Commission designated ChatGPT as a very large online search engine, and Reddit and Roblox as very large online platforms, under the Digital Services Act.

These designations are based on a quantitative criterion: the services reported having an average of at least 45 million monthly users in the EU, the threshold required by the Digital Services Act (DSA) for a service to be classified as systemic.

ChatGPT is therefore classified as a hybrid service falling under the regime for online search engines, due to its ability to interact with users and carry out web searches, despite its conversational and generative nature.

Reddit and Roblox, meanwhile, are classified as online platforms, as they enable users to distribute third-party content to the public: community discussions in the case of the former, and user-generated games in the case of the latter.

The services have four months, until January 2027, to comply with the additional obligations applicable to them.

The assessment and mitigation of systemic risks posed by their algorithmic systems, across six categories:

• the dissemination of unlawful content;
• adverse effects on minors;
• users’ physical and mental wellbeing;
• fundamental rights;
• electoral processes;
• public safety.

This analysis requires a risk assessment, proportionate mitigation measures, and an annual independent audit submitted to the authorities.

The Commission will have powers to investigate the functionality of these services. It will monitor compliance with the DSA in conjunction with the relevant Irish authority for ChatGPT, and with the relevant Dutch authority for Reddit and Roblox, which act as coordinators for the countries of establishment.

A regime that supplements rather than replaces: Roblox, Reddit and ChatGPT were already subject to the general obligations applicable to platforms and search engines. The designation adds a further layer of obligations, commensurate with their influence, which is now deemed to be systemic.

The Commission has now designated 28 very large platforms and search engines under the DSA, a list set to grow as new services cross this threshold.

FIRSH’s inputs

This designation confirms that the criterion for falling under the DSA’s enhanced regime remains purely quantitative, paving the way for its application to other generative AI systems with search functionality, as soon as they exceed this audience threshold.

Our teams assist digital sector stakeholders in identifying the obligations to which they are subject under the DSA and in ensuring compliance with them.

Claire Poirson & Léa Monel