ChatGPT, Reddit and Roblox face the EU's toughest platform rules. Here's what that changes for social marketers.
The European Commission designated ChatGPT as a Very Large Online Search Engine and Reddit and Roblox as Very Large Online Platforms under the Digital Services Act on August 31. All three services declared at least 45 million average monthly EU users, meeting the threshold for designation. They have four months, until the end of November 2026, to meet the DSA's additional obligations for very large platforms and search engines.
The designations aren't enforcement findings. They're regulatory categorisations that trigger a set of compliance requirements stricter than anything these platforms have faced in Europe before. And for social media marketers, the implications go further than you might think.
What just changed, and why it matters now
The designation proves particularly consequential for ChatGPT because the Commission has concluded that an AI chatbot that pulls live results from the internet functions, in regulatory terms, as a search engine. ChatGPT's search function averaged about 159 million monthly active users in the bloc for the six months ending March 2026, while Reddit reported 57.2 million and Roblox roughly 48 million.
For ChatGPT, the decision creates a second major layer of EU oversight, as OpenAI already faces obligations under the EU AI Act governing general-purpose AI models and AI-generated content.
With the addition of ChatGPT, Reddit and Roblox, the EC now designates 28 services as very large online platforms or search engines. That puts them in the same category as Meta's Facebook and Instagram, TikTok, YouTube, Google Search and Amazon's marketplace.
The practical consequence: the EC will supervise these platforms more closely for compliance with the DSA, including requiring the sharing of data with the commission and authorities, annual reviews from independent auditors and allowing researchers to access a platform's data in certain cases.
The obligations that now apply
Very large platforms and search engines face the most stringent obligations under the DSA. VLOPs and VLOSEs are subject to the most stringent set of obligations due to their reach and role in facilitating the spread of ideas, access to information, public debate and economic transactions, increasing their potential to pose systemic societal risks.
The core requirements include:
Risk assessment and mitigation. The designations place the three services under direct Commission supervision and give them until January 2027 to comply with additional risk-management, auditing and transparency requirements. Platforms must identify systemic risks, including those related to illegal content, harm to minors, and effects on public discourse, then put mitigation measures in place.
Content moderation transparency. VLOPs and VLOSEs must report on content moderation, including the human resources dedicated to content moderation, the qualifications and training of those individuals, and the accuracy of any automated content moderation conducted. Every time content is restricted or removed, platforms must issue a Statement of Reasons and log it in the DSA Transparency Database.
Advertising transparency. The DSA requires VLOPs to compile and publish advertisement repositories that detail certain information about advertisements, advertisers, targeting parameters and customer reach, and this applies to all advertisements, including commercial advertisements.
Algorithm disclosure. Platforms must provide information on how their recommender systems work and offer users the option of a non-personalised feed.
Independent audits. Designated services must undergo annual independent audits of their DSA compliance and publish the results.
Penalties for non-compliance can reach up to 6% of global annual turnover.
These new designations mean that ChatGPT, Reddit and Roblox will now be held to a higher standard of scrutiny and accountability in the European Union, in line with their large impact on our citizens and society.
Henna Virkkunen, Executive Vice-President for Tech Sovereignty, Security and Democracy, European CommissionWhat this means for marketers running campaigns on these platforms
Reddit and Roblox: moderation uncertainty and reach volatility
Both platforms now face heightened scrutiny of how their recommendation systems surface content, particularly content that reaches minors. Roblox combines gaming, social interaction and user-created virtual environments, with a particularly significant audience among children and teenagers. That makes it a priority target for regulators focused on child safety and addictive design patterns.
For brands running campaigns on either platform, the immediate risk isn't that your content will be removed. It's that the systems determining how far that content travels are about to change, potentially mid-flight, and you won't get advance notice.
Platforms under active DSA supervision have already experienced this. TikTok and Instagram have both faced regulatory pressure to reduce the weight of pure engagement signals in their recommendation algorithms. When that happens, organic reach from branded content and influencer partnerships can drop sharply, even when the content itself hasn't changed.
Roblox is the first game to be classified as a VLOP, which sets a precedent for how user-generated gaming platforms will be regulated in Europe. Brands building experiences or running activations inside Roblox should expect fresh compliance requirements around how those experiences are promoted and moderated.
ChatGPT: a new surface for brand visibility, now under scrutiny
ChatGPT's designation as a search engine is the bigger structural shift. It establishes that conversational AI tools pulling live web results will be regulated the same way Google Search and Bing are, not as experimental tech sitting outside the existing framework.
For search marketers and content strategists, this opens two questions. First, if ChatGPT is now a regulated search engine, does your brand have a strategy for how it appears in ChatGPT responses? Second, what happens to that visibility when the platform is forced to increase transparency around how it ranks and surfaces information?
The advertising transparency requirements that apply to very large search engines mean that any paid placements or sponsored content surfaced through ChatGPT will need to be disclosed in a public repository. Brands experimenting with generative AI as a discovery channel should be prepared for that visibility to become a compliance obligation, not just a nice-to-have.
The Brussels Effect is already reshaping campaigns globally
The DSA, like prior EU regulations of social media platforms, will further instantiate the Brussels Effect, whereby EU regulators wield powerful influence on how social media platforms moderate content on the global scale, because the DSA's regulatory regime (with its huge penalties for noncompliance) will incentivize the platforms to skew their global content moderation policies toward the EU's instead of the U.S.'s balance of speech harms versus benefits.
That's not a theoretical concern. It's already happening. Platforms rarely build region-specific moderation systems when the compliance cost of getting it wrong in the EU is that high. The safer play is to apply the stricter standard everywhere.
For global campaigns, that means EU-driven changes to how Reddit, Roblox and ChatGPT handle content and recommendations will likely show up in other markets too, even where the DSA doesn't formally apply. Marketers running multi-region campaigns should model what happens to performance if these platforms default more users into chronological, non-algorithmic feeds or tighten content eligibility for recommendation.
What to do now
Audit your EU exposure. If you're running paid social or influencer campaigns targeting European audiences on Reddit, Roblox, or integrating ChatGPT into content discovery strategies, document your current targeting parameters and content formats. The DSA's advertising transparency registry makes that information public record for EU-facing campaigns. If your targeting has been loose, tighten it before it becomes a documented compliance gap.
Model the reach impact. Run scenario planning for what happens if these platforms are required to change how their recommendation algorithms work. Brands over-reliant on algorithmic amplification for organic reach should treat this like a budget contingency exercise. What does performance look like if discovery is throttled?
Watch the enforcement pattern. The Commission has already opened DSA proceedings against X, TikTok, Meta and AliExpress. The Commission fined AliExpress €550 million in July 2026. Enforcement is live, not theoretical, and the focus areas (child safety, addictive design, transparency) overlap heavily with how Reddit and Roblox operate.
Don't treat this as an EU-only issue. The logic driving DSA compliance will influence platform policies globally. Build toward the strictest applicable standard now, rather than patching region by region later when enforcement pressure increases.
The broader shift
The ChatGPT designation is the clearest signal yet that the EU is treating AI-powered information tools as platforms, not just models. That has implications well beyond OpenAI. Every generative AI service with a search function and a European user base above 45 million is now on the clock.
For marketers, the lesson is simpler: the platforms you've built campaigns around are being re-regulated in real time, and the changes are being driven by compliance requirements that prioritise child safety, transparency and systemic risk over reach and engagement. The era of optimising for pure engagement signals without regulatory friction is ending. Plan accordingly.

