Scale finally comes with a compliance date.

On 31 August 2026, 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. Each service declared at least 45 million average monthly users in the European Union, the threshold that triggers the law’s additional obligations.

The companies have four months—until January 2027—to comply. Designation is not a finding that any of them has broken the law. It is recognition that systems operating at this scale can create risks that cannot be treated as a series of isolated support tickets.

The risk register becomes part of the product

The additional duties include assessing and mitigating systemic risks connected to illegal content, harms to minors, physical and mental wellbeing, fundamental rights, elections and public security. That changes what responsible product work looks like: ranking, recommendation, moderation and model behaviour need documented failure modes, controls and evidence that those controls work.

For an AI answer service, the important questions include how sources are selected, how unsafe outputs are measured and how a person challenges a decision. For a social or gaming platform, they include how recommender systems amplify material, how child users are protected and whether commercial incentives undermine those protections.

User choice needs a visible interface

The DSA already gives users routes to report illegal content, understand moderation decisions and challenge them. Very large platforms must also maintain advertising libraries and offer at least one recommendation option that is not based on profiling.

Those rights only matter if they survive implementation. A non-profiled feed hidden behind six settings screens is formal compliance without practical agency. The January deadline should be judged in the product itself: clearer explanations, usable appeals and controls that are as easy to reach as the features they govern.