On August 31, the European Commission designated ChatGPT as a Very Large Online Service (VLOSE) under the Digital Services Act (DSA). OpenAI is required to meet additional obligations by January 2027, including the assessment and mitigation of systemic risks associated with the service.
Reddit and Roblox have also been classified as Very Large Online Platforms (VLOP). This designation is granted to services that are used by an average of at least 45 million users per month in the EU.
According to OpenAI, from October 2025 to March 31, 2026, the search functions of ChatGPT were used by an average of approximately 159.1 million users each month in the European Union, which is more than three times the threshold for VLOSE status.
As a result, ChatGPT is now subject to specific DSA requirements for the largest online services. The developer company will need to identify, assess, and mitigate systemic risks related to:
- the spread of illegal content;
- protection of minors;
- the physical and mental well-being of users;
- fundamental rights;
- elections and public safety.
OpenAI is also required to establish an internal compliance function for DSA requirements, undergo an independent audit at least once a year, and provide data to the European Commission and national regulators.
Verified researchers will have the ability to request access to information needed to study systemic risks. Mitigation measures may involve altering the structure and operation of services, including their algorithmic and recommendation systems.
Violations of the DSA could result in fines of up to 6% of a company's global annual turnover for the largest online platforms and search engines. The regulator also has the authority to demand rectification of identified breaches.
It is worth noting that in August, the European Commission gained the authority to impose fines on providers of general-purpose AI models for violations of the Artificial Intelligence Act.