Which U.S. technology companies are expected to be designated as "very large online platforms" under the EU's Digital Services Act as soon as August 2026, what user threshold triggered this classification, what compliance obligations and fines will they face, and how do ChatGPT a

The User Threshold

The DSA classifies any online platform or search engine as a VLOP when it has 45 million or more average monthly active recipients in the EU — equivalent to roughly 10% of the EU's population . This threshold is defined in Article 33 of the DSA regulation . Platforms must self-report their user numbers every six months, and the Commission designates them when the 45-million mark is exceeded .

Compliance Obligations

Once designated, VLOPs have four months to comply with the DSA's most stringent rules . The key obligations include :

• Annual systemic risk assessments — evaluating risks related to illegal content, disinformation, electoral manipulation, and harms to minors
• Risk mitigation plans — detailing specific measures to address identified risks
• Annual independent audits — ensuring compliance with all DSA obligations
• Transparency reports — publishing detailed reports on content moderation decisions and practices
• Data access for vetted researchers — providing qualified researchers access to platform data
• Public advertisement repositories — maintaining searchable databases of all ads served
• Annual supervisory fee — paid to the European Commission to fund DSA enforcement

The European Commission has exclusive supervisory authority over VLOPs for systemic risk obligations .

Potential Fines

Companies that breach DSA rules risk fines of up to 6% of their annual global turnover (worldwide revenue) . The Commission can also impose periodic penalty payments for continued non-compliance. Recent enforcement actions demonstrate the scale: AliExpress was fined €550 million in July 2026 for failing to address unsafe/counterfeit products, and X was fined €120 million in December 2025 for deceptive design and lack of transparency .

ChatGPT and Roblox vs. the 45-Million Threshold

Both ChatGPT and Roblox have surpassed the 45-million monthly active user mark in the EU, which is what triggered their pending VLOP designation . The exact user figures disclosed by each company to the Commission have not been published publicly, but the reports indicate they "surpassed" the threshold, meaning their EU monthly active user bases are above 45 million but specific numbers above that level remain confidential at this stage.

In summary: Both platforms clearly exceed the 45-million threshold, which is why they face designation — no exact figures above 45 million have been publicly confirmed beyond that they are above the line.