EU Designates ChatGPT, Reddit and Roblox Under Digital Services Act's Strictest Tier
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The Facts
- The European Commission designated ChatGPT a Very Large Online Search Engine under the EU's Digital Services Act (DSA) on Monday.
- The Commission designated Reddit and Roblox as Very Large Online Platforms under the same law.
- ChatGPT is the first AI chatbot placed under the DSA's strictest tier of rules.
- The designation applies to services reporting at least 45 million average monthly users in the EU.
- The three services have four months to meet the additional DSA obligations.
- The obligations require the services to assess and mitigate systemic risks arising from their algorithmic systems.
- Those risks include harms to minors, illegal content, election integrity and public security.
- Non-compliance with the DSA can carry fines of up to 6% of global annual revenue.
- Roblox is a gaming platform widely used by children and teenagers.
- EU technology chief Henna Virkkunen said the three services will be held to a higher standard of scrutiny and accountability.
- The Commission has already opened DSA proceedings against platforms including TikTok, Facebook, Instagram and Snapchat.
Context
What is the Digital Services Act and what does the 'very large' label change?
The DSA is the EU's main law for regulating large online services; it entered into force in 2022 and applied in full from February 2024 infobae,T-online.de. Services with more than 45 million average monthly users in the 27-nation bloc are designated 'very large' platforms or search engines and face the law's strictest tier, including duties to assess and mitigate systemic risks and to submit to direct EU supervision and investigative powers NDTV,Terra,MARCA.
How large are these services in the EU?
All three reported passing the 45 million monthly user threshold uol.com.br,NDTV. ChatGPT's reported figures are well above it: German outlets cite more than 100 million monthly EU users reported for 2025, while La Repubblica reports 159 million in Europe N-tv,La Repubblica. Reddit reported 57.2 million users uol.com.br. With the new designations, the EU's list covers 28 platforms and search engines uol.com.br.
When exactly is the compliance deadline?
Sources consistently report a four-month window from notification but give differing end dates: some say late November infobae,Corriere della Sera, others end of December 2026 Sözcü Gazetesi, and others January 2027 MARCA,La Repubblica. The Commission has not been reported as publishing a single confirmed date across these accounts.
Has the EU enforced the DSA against other companies?
Yes. The Commission has opened more than a dozen formal investigations since 2023 and issued penalties reported to exceed €870 million, including €550 million against AliExpress, €200 million against Temu and €120 million against X, with proceedings open against Meta, TikTok and Shein infobae,ZEIT ONLINE,newsORF.at.
Where Left and Right agree, and where they split
- Where Left and Right agree
- Reach alone now triggers the strictest tier, and both reads treat 6% of global revenue as the provision that makes the obligation real rather than symbolic.
- Where Left and Right split
- Minors, voters and communities finally getting the burden of proof shifted onto the platform, or regulators acquiring design leverage over services that merely got large.
- Why they won’t converge
- The divide is trust in regulatory discretion: both readings accept the same 6%-of-revenue exposure, one as the only thing that makes risk audits more than paperwork, the other as leverage over product design, and no shared fact adjudicates that.
How left and right read it
When a service reaches 45 million people a month in the EU, the burden of proof belongs to the company, not to the kids, voters and communities absorbing whatever its algorithms produce. That is why the four-month clock on assessing and mitigating systemic risks — harms to minors, illegal content, election integrity, public security — matters, and why penalties reaching 6% of global revenue are the part that gives it teeth. Extending that duty to an AI chatbot for the first time is the obvious step. The question now is enforcement: will these assessments be tested, or merely filed?
Fines reaching 6% of global revenue are not a penalty for misconduct alone; they are leverage over how a service gets designed. That leverage attaches on reach alone — 45 million monthly EU users — so an AI chatbot now sits in the strictest tier, with four months to audit its own algorithmic systems for systemic risk. Penalties that sweeping demand rules that narrow.
“ChatGPT risks being forced to pay hefty fines under strict new rules enforced by Brussels.” — The Telegraph
The receipts — 100 sources
Wire services (3)
Independent coverage (97)
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