ChatGPT, Reddit and Roblox are now VLOPs — brand owners get DSA leverage on three new platforms
The European Commission designated ChatGPT a VLOSE and Reddit and Roblox VLOPs on 31 August 2026. By January 2027 all three carry heightened DSA duties — and brand owners gain notice-and-action and trusted-flagger leverage where clones and scams live.
By Ihor Makushinsky Counsel · with a note on every item On 31 August 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 having declared at least 45 million average monthly EU users. The services have four months — to January 2027 — to meet the heightened obligations: assessing and mitigating systemic risks from their services and algorithmic systems, including the dissemination of illegal content.
Why it matters
Designation is not symbolic. VLOP status upgrades every DSA mechanism a rights holder can invoke: notice-and-action under Article 16 comes under Commission-level supervision rather than national dispersion; trusted flaggers under Article 22 get priority processing; annual audits and risk-assessment duties make recurring abuse patterns — not just individual posts — the platform’s regulatory problem. And unlike the DMCA, the DSA’s “illegal content” reaches trademark infringement, scams and impersonation directly.
The three services matter for different reasons: Reddit hosts clone communities and “official” brand subreddits nobody authorised; Roblox carries branded experiences and virtual items trading on names their operators never licensed; ChatGPT’s designation as a search engine makes how it surfaces and reproduces brand information a supervised activity — a first for conversational AI.
What this means for you
If your brand fights recurring abuse on any of the three, the window before January 2027 is when compliance teams are building their processes — and when well-formed statutory notices get the most attention. File DSA notices that name the illegality precisely (trademark, consumer fraud, impersonation), keep records of unresolved reports — they feed systemic- risk arguments — and where volume justifies it, pursue trusted-flagger status through your national Digital Services Coordinator, or work through counsel who files at that standard.
Senior counsel · in IP and compliance practice since 2014. The counsel's note in every item is his own.
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