EU to designate ChatGPT and Roblox as high-risk digital platforms

This move signals the end of the regulatory 'grace period' for generative AI and gaming platforms in Europe. By pulling ChatGPT and Roblox into the same tier as Meta and Google, the EU is treating AI search and user-generated gaming environments as systemic infrastructure rather than emerging technologies. For the broader ecosystem, this sets a high-stakes precedent for how AI-driven recommendation and content systems must be audited. Success or failure here will define the operational overhead for any streaming or social platform scaling past 45 million users in the bloc. Watch for OpenAI's legal strategy regarding whether search-only figures can be used to regulate the entire chatbot interface.

The expected designation of ChatGPT and Roblox comes as the European Commission intensifies its enforcement of the Digital Services Act. Per Reuters and Bloomberg in July 2026, the Commission has already initiated more than a dozen probes into designated platforms. Recent enforcement actions have been severe; the Commission fined AliExpress €550 million in July 2026 and Temu €200 million in May 2026 for failing to properly mitigate the risk of illegal products, according to reporting from Mishcon de Reya and Silicon Republic.

For Roblox, the EU designation layers onto significant existing legal pressure regarding child safety. Per Tweaktown and Engadget (July 2026), the platform has faced multiple lawsuits in the United States from Louisiana, Texas, and Los Angeles County over alleged failures to protect minors. While Roblox has responded by introducing stricter social media age assurance and selfie-based verification, the DSA will now mandate independent audits of these systems. The entry of ChatGPT search into the VLOSE category also marks the first time a generative AI product has been forced to comply with these specific transparency and risk assessment rules.

OpenAI’s disclosure of 120.4 million average monthly active users—calculated specifically for ChatGPT's search features—has essentially locked the company into the VLOSE designation. According to a July 2026 update from OpenAI’s own transparency portal, this user count covers the six-month period ending March 31, 2026. This technicality is significant because it allows the EU to regulate the search-like output of AI differently than standard social platforms, potentially requiring OpenAI to report threats to authorities more proactively, a policy it adopted following criticism over a 2025 mass shooting investigation as noted by Engadget.