The ChatGPT designation is honestly the more interesting curveball here. The Commission decided that because ChatGPT can pull live results from the web in response to a prompt, it counts as a "hybrid service" that functions as a search engine under DSA rules — not just a chatbot. That's a first for any AI assistant, and it's a big deal precedent-wise: it means other AI tools with web-browsing or retrieval features could get pulled into the same bucket down the line. OpenAI reportedly disclosed around 159 million average monthly EU users for ChatGPT's search function, which is wildly over the threshold. Reddit and Roblox, meanwhile, got classified the more "traditional" way — as platforms where users publish and share content at scale (posts and discussions for Reddit, user-made games for Roblox), reporting roughly 57.2 million and 48 million monthly EU users respectively.
So what actually changes for these companies? They've got until the end of November 2026 (four months from designation) to comply with the DSA's heaviest obligations. That includes running annual systemic risk assessments covering things like the spread of illegal content, harm to minors, effects on mental wellbeing, impacts on elections and civic discourse, and risks tied to gender-based violence. They'll also need to submit to independent audits, hand over data access to regulators and vetted outside researchers, and generally operate with a lot more transparency than before. Supervision will be split between national regulators — Ireland's Coimisiún na Meán is handling ChatGPT (and reportedly Reddit too), while the Netherlands' Authority for Consumers and Markets takes point on Roblox — working in coordination with the Commission itself.
Here's the part that should get companies' attention: non-compliance under the DSA can trigger fines of up to 6% of a company's total global annual revenue, not just EU revenue. For a company like OpenAI, that's a genuinely massive number given how fast ChatGPT's user base has grown. It's also worth noting these designations aren't findings of wrongdoing — they're a classification that unlocks stricter scrutiny going forward. But given the EU's track record of aggressive DSA enforcement against platforms like X and TikTok, it's a safe bet that ChatGPT, Reddit, and Roblox are about to get a lot more attention from Brussels than they're used to.Sources
- European Commission — Official Press Release
- Lexology — "When a Chatbot Becomes a Search Engine"
- Hunton Privacy & Cybersecurity Law Blog — Full Breakdown
