- The European Commission has designated Roblox as a Very Large Online Platform (VLOP) along with ChatGPT and Reddit, for exceeding 45 million monthly users in the EU.
- The deadline for complying with the additional DSA obligations has been set for the end of December 2026, including systemic risk assessments and independent audits.
- Roblox is overseen by the Netherlands Consumer and Market Authority (ACM), while ChatGPT and Reddit are overseen by the Irish coordinator.
- Failure to comply can result in fines of up to 6% of global turnover, as already happened with X (formerly Twitter) with a penalty of 120 million euros.
The European Union has grouped Roblox, ChatGPT, and Reddit together. Last Monday, the European Commission announced that these three services exceed the threshold of 45 million monthly active users within the EU, which requires them to comply with the stricter rules of the Digital Services Act (DSA). Specifically, Roblox has been classified as a Very Large Online Platform (VLOP) , while ChatGPT has been reclassified as a Very Large Online Search Engine (VLOSE) due to its integrated search function.
This designation is not a judgment on the security of the platforms, but simply a matter of size. The legal threshold is 45 million average monthly active users in the EU, and companies report their own figures. Roblox has exceeded this threshold by a very narrow margin: just 1,6 million users above it. According to the reported data, the immersive gaming platform has around 48 million users in the bloc, while Reddit reached 57,2 million and ChatGPT, in its search function, soared to 159,1 million. This is the first time an AI chatbot has been subject to the DSA in its search engine category.
Obligations and deadlines for Roblox
The three companies now have four months to adapt to the new requirements , setting the deadline at the end of December 2026. From then on, they will have to conduct annual systemic risk assessments covering the distribution of illegal content, the protection of minors, negative effects on users' physical and mental health, respect for fundamental rights, electoral processes, and public safety. They will also have to open their systems to independent audits and share data with accredited regulators and researchers.
The European Commission is assuming new powers to investigate the internal workings of these services, and oversight will be carried out in collaboration with the digital services coordinators in each country. In the case of Roblox, the responsible entity will be the Netherlands' Consumer and Markets Authority (ACM) , given that the platform's European headquarters are located in the Netherlands. ChatGPT and Reddit, meanwhile, will fall under the supervision of the Irish authority, Coimisiún na Meán.
The EU's Executive Vice-President for Technological Sovereignty, Security and Democracy, Henna Virkkunen, has made it clear that the Commission "will not hesitate to designate any platform that meets the threshold for enhanced supervision" and that these new designations mean that ChatGPT, Reddit and Roblox "will now have a higher level of control and accountability in the European Union, in line with their significant impact on our citizens and society."
The precedent of fines and the European context
This isn't the first time the DSA has been applied with a firm hand. The Commission has already imposed fines totaling around €870 million since the law came into effect. Among the most notable penalties is that of X (formerly Twitter), fined €120 million in December 2025 for breaches in content moderation and transparency. There are also precedents with AliExpress (€550 million) and Temu (€200 million). If Roblox or any of the other services fail to comply with the DSA obligations, they face penalties of up to 6% of their global turnover, a figure that, in the case of OpenAI, could be substantial.
Roblox's designation as a VLOP also has implications for the platform's economy. Roblox allows users to create, publish, and play games developed by others, making it an ecosystem of user-generated content. Now, the platform will have to implement measures to strengthen child safety with AI and prevent the spread of illegal content, an aspect that has been criticized in the past. The company will also have to undergo external audits to verify that its algorithmic systems do not amplify systemic risks.
In the European context, this decision comes at a time of trade tension with the United States. The US administration has described the EU fines against Apple and Meta as a "novel form of economic extortion" and has threatened retaliation. The inclusion of three US services under direct Brussels supervision could fuel this rhetoric, although the Commission maintains that the DSA is a neutral law that applies to any platform that reaches the threshold, regardless of its country of origin.
In addition to Roblox, the Commission has already designated 28 major platforms and search engines under the DSA, including Google, Meta, TikTok, and Amazon. Oversight is shared between the Commission and national coordinators, ensuring consistent application across the country. For European users, this means they will have more tools to report illegal content and that platforms will be required to be more transparent about their recommendation and advertising systems.
The four-month period will end in late December 2026, at which point Roblox, ChatGPT, and Reddit must submit their initial risk assessments. Following this, the Commission will decide whether the measures taken are sufficient or whether to open sanction proceedings. In the meantime, the ball is in the platforms' court, and they will have to demonstrate that they are taking their legal obligations in the European digital single market seriously.