EU Signals Possible DSA Designation for ChatGPT, Roblox
European Commission spokesperson Thomas Regnier said on July 30 that ChatGPT and Roblox could be designated as very large online platforms or search engines under the Digital Services Act. He said both services had reported user numbers above the relevant threshold, making designation "definitely possible" and potentially forthcoming "sooner or later." No formal designation has been announced.
ChatGPT and Roblox could be added to the European Union's list of very large online platforms or search engines under the Digital Services Act, European Commission spokesperson Thomas Regnier said on July 30, according to a Reuters report carried by The Economic Times.
Regnier said both services had announced user numbers above the DSA threshold. He described a designation as "definitely possible" and said it could come "sooner or later." The Commission had not formally designated either service in the materials retrieved for this report.
Threshold and regulatory obligations
European Commission guidance says platforms or search engines with more than 45 million monthly EU users can be designated as very large online platforms or very large online search engines. After designation, a service has four months to comply with the enhanced DSA obligations.
OpenAI's DSA information page reports that ChatGPT search had approximately 159.1 million average monthly active recipients in the EU during the six months ending March 2026. Heise reported Roblox's corresponding audience at about 48 million, citing the company's figures and Bloomberg reporting.
The Commission's guidance says designated services must assess and mitigate systemic risks, maintain an internal compliance function, undergo an independent audit at least annually, provide data to regulators and vetted researchers, and publish transparency information about advertising and recommender systems. Heise also reported that DSA violations can lead to fines of up to 6% of worldwide annual turnover.
A possible new application of the DSA
A ChatGPT designation would apply the DSA's largest-service regime to a prominent conversational AI product. The immediate development remains regulatory rather than technical: no formal decision, implementation timetable, or ChatGPT-specific compliance instructions have been published.
For AI practitioners, the relevant engineering questions concern audit trails, risk documentation, transparency reporting, and access to operational evidence. How the Commission would apply those obligations to ChatGPT search and other conversational features remains open until it issues a designation decision and supporting details.
Roblox has a different service model, but the possible designation places both services under the same audience-threshold framework. Teams should distinguish the spokesperson's statement that designation is possible from a completed designation carrying enforceable deadlines.
Key Points
- 1The Commission spokesperson said ChatGPT and Roblox had reported user numbers above the relevant DSA threshold, making formal designation possible.
- 2The Commission's DSA guidance says designated services have four months to meet enhanced risk, audit, transparency, and data-access obligations.
- 3OpenAI reports 159.1 million average monthly active ChatGPT search recipients in the EU for the six months ending March 2026.
Scoring Rationale
Potential DSA designation would bring stricter EU platform oversight into direct relevance for ChatGPT and a major youth-oriented online platform. The formal decision and precise compliance requirements remain unannounced, but the case is important for AI teams building large-scale consumer services in Europe.
Sources
Public references used for this report.
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