The European Commission has placed ChatGPT, Reddit, and Roblox under direct EU supervision, ordering each service to assess and mitigate systemic risks within four months of receiving formal designation notices. Non-compliance can trigger penalties of up to 6% of a company’s global annual turnover.
Designations Under the Digital Services Act
The Commission’s move falls under the EU’s Digital Services Act (DSA), which subjects Very Large Online Platforms (VLOPs) and Very Large Online Search Engines (VLOSEs) to enhanced obligations and centralized oversight. Once designated, services must complete risk assessments, implement risk-mitigation measures, increase transparency around recommender systems and advertising, and submit to independent audits.
Direct Commission supervision allows Brussels to coordinate enforcement across member states and, where necessary, impose corrective actions. The four-month compliance window begins upon notification of designation.
Why ChatGPT Was Classified as a Search Engine
The Commission classified ChatGPT as a search engine on the basis that it enables users to submit queries and receive synthesized, ranked, or curated information sourced from across the web—functionality that aligns with the DSA’s definition of an online search engine. This designation places ChatGPT under VLOSE-style obligations focused on transparency, systemic risk management, and safeguards around how results are generated and displayed.
Key Obligations and Enforcement
- Conduct and document comprehensive risk assessments, including risks related to disinformation, manipulation, consumer protection, and the protection of minors.
- Deploy proportionate risk-mitigation measures and establish internal compliance and governance processes.
- Provide greater transparency on algorithms and recommender systems, including user-facing disclosures.
- Offer data access to vetted researchers to study systemic risks.
- Undergo independent compliance audits and cooperate with Commission monitoring.
Failure to meet these requirements can result in fines of up to 6% of global annual turnover, alongside potential remedial measures or periodic penalties until compliance is achieved.
Implications for Digital Asset Content
Reddit’s designation is likely to affect moderation and discovery of crypto-related communities and advertising within the EU, while search and content curation obligations for ChatGPT may influence how crypto information and market data are surfaced to users. Increased transparency and risk controls could also impact the visibility of fraudulent schemes and the labeling of financial promotions across these services.
All three companies must now finalize and implement their risk assessments and mitigation plans within the prescribed four-month window, after which the Commission will review compliance and determine any further supervisory steps.