EU: ChatGPT, Reddit, and Roblox to be subject to DSA by 2026

ChatGPT, Reddit, and Roblox fall into the category of "very large" services under the DSA. This designation triggers specific transparency requirements and limits advertising targeting, with a compliance deadline set for the end of December 2026.

Compliance Required by December 2026 in the EU

ChatGPT, Reddit, and Roblox have until the end of December 2026 to comply with the obligations set forth by the DSA. "These new designations mean that ChatGPT, Reddit, and Roblox will now be subject to a higher level of oversight and accountability in the European Union," says Henna Virkkunen, Executive Vice President in charge of technological sovereignty, security, and democracy. She justifies this level of oversight by the significant impact these services have on citizens and society.

Advertising to Minors Prohibited and Enhanced Transparency

The DSA prohibits targeted advertising to minors. It also bans the use of sensitive data such as sexual orientation, religion, ethnicity, or political beliefs for advertising purposes. Additionally, it requires increased transparency regarding the functioning of recommendation algorithms. OpenAI will also need to consider the risks associated with ChatGPT's influence on minors, the mental health of users, and the circulation of illegal content within the European Union.

VLOP/VLOSE Designations and the 45 Million User Threshold

ChatGPT is now classified among the very large online search engines according to the DSA. The European Commission has also granted this status of very large online platform to Reddit and Roblox, which must therefore comply with the same requirements. The DSA specifies that an online platform or search engine qualifies as "very large" once it has at least 45 million average monthly users in the European Union. This legislative framework governs major online services and platforms.