On August 31, the European Commission designated ChatGPT as a VLOSE under the Digital Services Act (DSA). OpenAI must meet additional requirements by January 2027, including assessing and mitigating systemic risks of the service.
The regulator also recognized Reddit and Roblox as VLOP. This status is given to services with an average of at least 45 million monthly users in the EU.
According to OpenAI, from October 2025 to March 31, 2026, ChatGPT’s search functions had an average of about 159.1 million monthly users in the EU, more than three times the threshold for VLOSE status.
ChatGPT is now subject to specific DSA requirements for major online services. The developer company must identify, assess, and mitigate systemic risks related to:
- the dissemination of illegal content;
- the 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 independent audits at least annually, and provide data to the European Commission and national regulators.
Verified researchers will be able to request access to information necessary for studying systemic risks. Mitigation measures may include changes to the design and operation of services, including their algorithmic and recommendation systems.
Violations of the DSA by major online platforms and search engines could result in fines of up to 6% of the company’s global annual turnover. The regulator also has the authority to demand the rectification of identified violations.
Earlier, 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.
