On August 31, 2026, the European Commission designated ChatGPT a Very Large Online Search Engine (VLOSE) under the Digital Services Act, and designated Reddit and Roblox as Very Large Online Platforms (VLOPs). The trigger is a numeric threshold, not a discretionary judgment: each service declared that it reaches at least 45 million average monthly users in the European Union, the point at which the DSA’s heaviest tier of obligations attaches.
The designated services have four months, until January 2027, to comply with the additional VLOP and VLOSE duties. Those duties centre on systemic risk: each service must assess and mitigate risks arising from the dissemination of illegal content, negative effects on minors and on users’ physical and mental well-being, harm to fundamental rights, interference with electoral processes, and threats to public security. In practice that means annual risk assessments, independent audits, a mitigation plan the Commission can interrogate, data access for vetted researchers, and direct Commission supervision rather than supervision by a single member state regulator.
This matters because it is the clearest sign yet that Europe intends to govern general-purpose AI assistants through two stacked regimes rather than one. The AI Act’s transparency obligations began to be enforced on August 2, 2026, and the DSA now layers systemic risk management on top for the largest assistants. Any AI product that crosses 45 million EU monthly users should expect the same treatment, and should be planning risk assessment and audit capacity well before it does.