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The European Commission Has Designated Major Digital Platforms and Search Engines Under the Digital Services Act

An announcement regarding the designation of ChatGPT, Reddit and Roblox under the Digital Services Act (“DSA”) was published by the European Commission (“Commission”) on 31 August 2026.

The following matters were addressed within the scope of the announcement:

  • ChatGPT has been designated as a Very Large Online Search Engine (“VLOSE”), while Reddit and Roblox have been designated as Very Large Online Platforms (“VLOPs”) under the DSA. The designations follow the declaration by the relevant service providers that these services have reached the threshold of at least 45 million average monthly active users in the European Union.
  • Following notification of the designations, the relevant services are required to comply with the additional obligations applicable to VLOPs and VLOSEs under the DSA within four months, i.e. by January 2027.These obligations are in addition to the general obligations already applicable to online platforms and search engines under the DSA.
  • The additional obligations include the assessment and mitigation of systemic risks arising from the operation of the designated services and their systems. In particular, these risks concern the dissemination of illegal content, negative impacts on minors, users’ physical and mental well-being, fundamental rights, electoral processes and public security.
  • The VLOP and VLOSE framework further provides for a number of enhanced transparency, accountability and oversight obligations. These include the establishment of points of contact for authorities and users, mechanisms for reporting crimes, user-friendly terms and conditions, increased transparency regarding advertisements, recommender systems and content moderation decisions, independent annual audits, data access for the Commission and national authorities, and access to relevant data for qualified researchers conducting research into systemic risks. Designated services are also required to provide users with an option for a recommender system that is not based on profiling and to maintain a publicly accessible advertising repository.
  • The Commission is directly responsible for supervising VLOPs and VLOSEs under the DSA. In exercising its supervisory powers, the Commission cooperates with the relevant national Digital Services Coordinators. In the case of the newly designated services, the relevant national authorities include the Digital Services Coordinators in Ireland and the Netherlands, where the respective entities are established.
  • The designations do not, in themselves, constitute a finding of an infringement or the imposition of a sanction. Rather, they subject the designated services to the enhanced regulatory framework applicable to VLOPs and VLOSEs under the DSA.
  • Following these designations, the number of services designated as VLOPs and VLOSEs in the European Union has increased to 28.
  • The designation of ChatGPT as a VLOSE is particularly significant in terms of the application of the DSA to AI-based services providing web-search functionality. The designation means that ChatGPT is subject to the enhanced obligations applicable to VLOSEs, including the specific requirements concerning systemic risk assessment and mitigation.

 

You can access the full text of the announcement here.

 

 

 

 Kind regards,

   Zumbul Attorneys-at-Law

info@zumbul.av.tr

 

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