The European Commission has classified OpenAI’s ChatGPT as a Very Large Online Search Engine (VLOSE) and Roblox and Reddit as Very Large Online Platforms (VLOPs) under the Digital Services Act, triggering significant new compliance demands for these services by year-end.
- ChatGPT designated as VLOSE, Roblox as VLOP under EU Digital Services Act
- New transparency requirements include audits and public access for researchers
- Implementation complexity arises from hybrid service models and recommender systems
What happened
On August 31, the European Commission officially designated OpenAI’s ChatGPT as a Very Large Online Search Engine (VLOSE) while categorizing Roblox and Reddit as Very Large Online Platforms (VLOPs) under the Digital Services Act (DSA). This designation applies to platforms that reach at least 45 million average monthly users in the European Union. These platforms must now comply with additional transparency and accountability obligations.
Among these requirements, ChatGPT, Roblox, and others must allow third-party auditors chosen by the platforms themselves as well as independent researchers and the public to inspect their systems and algorithms. This approach aims to shed light on how content is recommended or prioritized, a crucial move as these platforms significantly influence online information and user interactions.
Why it matters
These designations mark a significant evolution in how EU digital law applies to services that have grown beyond their original classifications. Roblox’s inclusion recognizes the convergence between gaming and social media, given its user-generated content and interactive social features. Similarly, ChatGPT’s hybrid model as both chatbot and live search engine pushes the boundaries of existing regulatory definitions.
The transparency obligations address growing concerns about the power and opacity of recommender systems, user profiling, and information control. For Roblox, these measures are relatively straightforward, but for ChatGPT, synthesizing search results and defining non-profiling recommendations present novel challenges. The decisions reinforce the EU’s commitment to adapting the regulatory framework to reflect dynamic digital ecosystems.
What to watch next
The coming months will be critical as ChatGPT, Roblox, and other newly designated VLOPs and VLOSEs implement the mandated changes by December. Industry observers will closely monitor how these platforms meet demands for transparency, provide alternative recommender options, and navigate public scrutiny of their algorithms.
Particular attention will focus on the technical and legal debates over the meaning of profiling, the role of persistent user memory in AI responses, and how synthesized versus ranked search results fit within the DSA framework. The EU’s enforcement and interpretation approach could set precedents for regulating other hybrid and AI-powered digital services worldwide.