The European Commission today designated ChatGPT as a Very Large Online Search Engine and Reddit and Roblox as Very Large Online Platforms under the Digital Services Act, bringing three services with a combined declared reach of 262.9 million average monthly users in the European Union inside the regulation's heaviest compliance tier. All three have until the end of December 2026 to comply.

The designation decisions, published in Brussels on August 31, 2026 under reference IP/26/1772, rest on figures the companies themselves put on the record. According to the Commission, the three services declared that they reach at least 45 million average monthly users in the EU, which is the statutory threshold for designation. The Commission's supervision page for designated services, updated the same day, puts numbers against each name: ChatGPT at 159.1 million average monthly active users, Reddit at 57.2 million, and Roblox at 46.6 million.

Those figures carry a caveat printed on the Commission's own page. User counts are reported by the provider, drawn from transparency reports or company websites, and published without prejudice to any Commission assessment of the methodology used to calculate active recipients of the service. In other words, the numbers that triggered designation are the numbers the companies supplied.

Three services, three different routes into the regime

The classifications are not identical, and the differences matter for what each company now has to do.

ChatGPT enters as a Very Large Online Search Engine, the smaller of the two categories. Until today it contained two services: Google Search, with 364 million declared monthly users, and Microsoft's Bing, with 119 million. The Commission's reasoning for placing an AI assistant in that bracket is set out in a single paragraph. ChatGPT is described as an artificial intelligence system that engages with and responds to user prompts and queries, including by searching the web, which makes it a hybrid service qualifying as an online search engine under the regulation.

That framing is consequential. The search engine category attracts obligations on ranking transparency, risk assessment and data access, and it now applies to a conversational interface rather than a list of blue links. ChatGPT joins the list at 159.1 million declared monthly users, well below Google Search but above Bing.

Reddit and Roblox enter as Very Large Online Platforms. The Commission's stated basis is that both allow users to disseminate third-party content to the public: Reddit as a discussion-based service organised into topic-based communities, Roblox as a platform on which users create, publish and play games built by others.

Roblox at 46.6 million sits 1.6 million above the designation threshold. That margin is the thinnest of any currently designated service other than XNXX, listed at exactly 45 million. A platform that drops below the line can be de-designated: the Commission terminated Stripchat's designation on May 27, 2025, after which the additional obligations ceased to apply four months later.

Where the Commission's own documents disagree

The press release and the supervision page do not tell the same story about who supervises Reddit.

According to the press release, the Commission will supervise compliance in cooperation with Coimisiún na Meán for ChatGPT and Reddit, and with the Authority for Consumers and Markets for Roblox, the two bodies serving as Digital Services Coordinators for Ireland and the Netherlands respectively. The supervision page, updated on the same date, lists Reddit's main establishment in the EU as Reddit Netherlands B.V. and its Digital Services Coordinator as the Netherlands, not Ireland. The two documents were published the same day and cannot both be correct on that point.

Roblox carries a further wrinkle. The supervision page records no EU main establishment for the company, noting instead that Roblox appointed a legal representative in the EU based in the Netherlands. Article 13 of the regulation requires providers without an establishment in the Union to designate such a representative, who can be held liable for non-compliance. The Wikimedia Foundation, incorporated in the United States, appears on the same list under a comparable arrangement.

OpenAI Ireland Limited is named as the main establishment for ChatGPT, placing it with Coimisiún na Meán. The Dublin entity is the same one that appears as data controller in OpenAI's European privacy policy, an arrangement that gives the Irish Data Protection Commission lead supervisory authority for data protection matters and has been documented in detail alongside the company's European advertising rollout.

Four months, and what has to be built inside them

The clock runs from notification of the designation to the end of December 2026. Within that window, according to the Commission, the three services must comply with the additional obligations applicable to very large platforms and search engines, including assessing and mitigating the systemic risks stemming from their services and algorithmic systems.

The regulation enumerates those risks. They cover the dissemination of illegal content, negative effects on minors, users' physical and mental well-being, fundamental rights, electoral processes and public security. Each designated service must produce a risk assessment before deploying functionalities likely to have a critical impact on the identified risks, submit to independent annual audits, publish an advertising repository, and open data to vetted researchers.

The Commission also gains investigative powers over the functionalities behind the designated services and, where applicable, any related system. That phrasing matters for ChatGPT, where the boundary between the assistant, its web search behaviour, its memory features and its advertising layer is not fixed. It also matters for Roblox, where the user-generated experience layer, the creator economy and the advertising stack are separate systems built on the same identity graph.

All three services were already subject to the general obligations that apply to online platforms and search engines. Designation adds the second tier rather than creating obligations from nothing.

The advertising rules that attach on designation

For media buyers, the operative sections are Articles 26, 28 and 39.

Article 26 requires per-advertisement transparency: who paid for the advertisement, on whose behalf it was presented, and which main parameters determined the recipient. Article 28(2) prohibits presenting advertisements based on profiling where the platform is aware with reasonable certainty that the recipient is a minor. Article 39 requires designated services to maintain a public advertisement repository, retained for a year after the last presentation, covering content, advertiser, period, targeting parameters and reach.

The European Data Protection Board set out where those duties collide with data protection law in Guidelines 3/2025, adopted on September 11, 2025. The guidance identified a sequencing problem: information required under Article 26 reaches the user after personal data may already have been processed. It also confirmed that the Article 26(3) prohibition on advertising based on profiling using special categories of personal data applies regardless of any derogation available under the General Data Protection Regulation.

Implementation guidance exists on the industry side. IAB Europe published version 1.2 of its DSA Transparency Implementation Guidelines on December 4, 2025, adding standardised disclosure text in 24 EU languages and defining targeting parameters that include cross-context behavioural profiling, contextual advertising without personalisation, and precise geolocation to within 500 metres.

Each of the three newly designated services carries live advertising exposure. ChatGPT began serving sponsored placements to Free and Go users in Europe in August 2026, with selection initially based on conversation topic, general location and device type rather than personalisation. Reddit reported second-quarter 2026 advertising revenue of 762 million dollars, a 64% year-on-year increase, and entered the S&P 500 with 130 million daily active users. Roblox runs immersive video and billboard formats through Magnite, PubMatic and Google, all restricted to users aged 13 and above, with SuperAwesome appointed in June 2026 as its sole third-party partner for contextual advertising to under-13s worldwide.

What the label has meant for those already carrying it

Designation is a supervisory status rather than a finding of wrongdoing. The enforcement record attached to it, however, is now substantial.

The Commission fined X 120 million euros on December 5, 2025 over advertising repository failures and other breaches, and opened an investigation on January 26, 2026 into Grok and X's recommender systems. It fined Temu 200 million euros on May 28, 2026 for failing to assess the systemic risks posed by illegal products, roughly two years after that platform was designated. AliExpress was fined 550 million euros on July 20, 2026. Preliminary findings have been issued against Meta's services on three separate occasions, including findings on addictive design across Instagram and Facebook on July 10, 2026, and against TikTok on four.

The Temu sequence gives the clearest read on timing. Designation on May 31, 2024, proceedings opened on October 31, 2024, preliminary findings on July 28, 2025, decision on May 28, 2026. The regulation sets no legal deadline for concluding proceedings.

National enforcement runs in parallel and moves at a different pace. Germany's Digital Services Coordinator acted on 1.3% of complaints in its first year, and six of the eight Article 40 researcher access applications it received by the end of 2025 were withdrawn.

Why the designation matters to the advertising market

The immediate commercial effect is not a change in ad formats. It is a change in what the three companies must be able to demonstrate about their own systems, and in what becomes visible to everyone else.

Three consequences follow for marketers. Advertisement repositories will expose campaign-level detail on services where none previously existed, including creative, targeting parameters and reach for every European advertiser on Reddit and Roblox. Risk assessments will force each company to document, in a form the Commission can examine, how its recommender and ad delivery systems interact with minors and with the dissemination of illegal content. And the Article 28 profiling prohibition acquires a supervisor with the power to test compliance rather than accept an assertion of it.

Roblox and Reddit have both already moved on minors. Reddit restricted chat, follower visibility and advertising personalisation for EU accounts identified as belonging to 13 to 15 year olds from June 24, 2026, citing compliance with EU law. The United Kingdom's Information Commissioner's Office fined the company 14.47 million pounds on February 24, 2026 over children's data failures. Roblox routes under-13 advertising through contextual rather than behavioural targeting.

For ChatGPT, the designation lands weeks after advertising arrived in the European market and while the boundary between an answer and a paid placement is still being drawn. A service designated as a search engine under the regulation is one whose ranking parameters must be disclosed and whose systemic risks must be assessed. Sponsored placements inside generated answers sit inside that perimeter.

A jurisdictional footnote applies throughout. The Digital Services Act binds in the 27 member states; incorporation into the EEA agreement remains pending, which means designation obligations do not automatically extend to Iceland, Liechtenstein and Norway even where the General Data Protection Regulation does. The separate Digital Markets Actregime, which governs gatekeeper conduct rather than systemic risk, is in the same position and covers none of the three companies designated today.

The Commission has now designated 28 very large online platforms and search engines. Executive Vice-President for Tech Sovereignty, Security and Democracy Henna Virkkunen framed the additions in terms of scrutiny rather than enforcement. "These new designations mean that ChatGPT, Reddit and Roblox will now be held to a higher standard of scrutiny and accountability in the European Union, in line with their large impact on our citizens and society," she said in the announcement.

Timeline

Summary

Who: The European Commission, acting through its Directorate-General for Communications Networks, Content and Technology, designated three services operated by OpenAI Ireland Limited, Reddit Netherlands B.V. and Roblox. Supervision involves Coimisiún na Meán as Ireland's Digital Services Coordinator and the Authority for Consumers and Markets as the Dutch equivalent. Executive Vice-President Henna Virkkunen made the accompanying statement.

What: ChatGPT was designated a Very Large Online Search Engine and Reddit and Roblox were designated Very Large Online Platforms under the Digital Services Act, on declared figures of 159.1 million, 57.2 million and 46.6 million average monthly active users in the EU. The designations add systemic risk assessment, independent audit, advertisement repository, researcher data access and recommender transparency obligations to the general platform duties the three services already carried, and bring the total number of designated services to 28.

When: The designations were adopted and published on August 31, 2026 under reference IP/26/1772. Compliance with the additional obligations is due four months after notification, by the end of December 2026.

Where: The obligations apply across the European Union. ChatGPT is supervised through Ireland, Roblox through the Netherlands via an appointed EU legal representative, and Reddit through establishments the Commission's press release and supervision page assign to different member states.

Why: The three services declared user numbers at or above the 45 million average monthly threshold that triggers designation, and the Commission gains investigative powers over the functionalities behind them. For the advertising market, the designations bring an AI assistant carrying sponsored placements, a discussion platform with 762 million dollars in quarterly advertising revenue and an immersive gaming platform with a large minor audience under the regulation's advertising transparency, repository and minor-profiling rules.