ChatGPT, Reddit and Roblox: what stricter EU oversight changes

ChatGPT, Reddit and Roblox are moving into the highest tier of supervision under the European Digital Services Act, known as the DSA. The European Commission announced the new designations on 31 August 2026. For users in Greece, the development mainly concerns the services' accountability for risks arising on a large scale. One distinction matters: the three services have not been placed in the same legal category. Official European Commission announcement.

How each service has been designated

The official list of designated services records this distinction. The size criterion relates to at least 45 million average monthly active recipients in the EU. The designation concerns the particular service and the corresponding set of obligations.

A designation is neither a fine nor a finding of an infringement. Penalties require a separate enforcement procedure and a specific decision. Headlines presenting the announcement as a “punishment” of the three services therefore give the event a different meaning. How DSA enforcement works.

When the additional obligations begin

The deadline is four months from notification of the designation to the respective provider. The Commission's main announcement, updated on 4 September 2026, places compliance by January 2027. The date of the press release alone does not justify calculating a specific final day. Announcement and compliance timetable.

This concerns the additional obligations for very large services. It does not mean that all DSA obligations first appear in 2027: the regulation became generally applicable on 17 February 2024, with different rules for different categories of provider. European Commission: application and supervision.

What changes for the companies in practice

Very large services must identify and address systemic risks: the dissemination of illegal content and effects on fundamental rights, the protection of minors, public security and electoral processes. Measures must respond to the risks of the particular service and may include changes to its design, content recommendations or mechanisms for handling notices. Additional obligations for VLOPs and VLOSEs.

In practical terms, supervision also looks at how a system operates as a whole. A recurring problem caused by design features that amplify particular risks needs an organised response. This is the practical significance of supervising algorithmic systems, as described by the European Centre for Algorithmic Transparency.

Independent audits are also required at least once a year. An audit creates an obligation to document compliance; it is not advance approval of every feature or a guarantee that no incident will occur. Official information on independent audits.

Where recommender systems are used, an option that is not based on profiling must also be provided. Where advertisements are displayed, the corresponding obligations concerning a public advertising repository apply. These requirements must be assessed in relation to the features each service actually provides. Transparency, recommendations and advertising.

Why ChatGPT requires a different legal reading

ChatGPT is listed as a VLOSE. This designation does not automatically turn every one of its features into an online platform. In particular, Articles 20 and 21 of the DSA concern specific decisions by providers of online platforms. They do not, by themselves, establish a general right to “appeal” against any chatbot answer. The distinction follows from the scope of the relevant provisions of Regulation (EU) 2022/2065.

For example, an inaccurate answer to a question differs from a platform's decision to remove a user's post. The appropriate legal response starts by identifying the problem: information accuracy, the processing of personal data, an account restriction or another act. The new designation does not justify promising that the same request will resolve all these situations.

Reddit and Roblox: how users can challenge decisions

Internal review by the platform

Article 20 provides for a free electronic complaint-handling system for the decisions it covers, such as the removal of content or an account restriction on grounds of illegality or incompatibility with the terms of service. Access must remain available for at least six months after the user is informed of the decision. Decisions on complaints must be taken under the supervision of appropriately qualified staff and must not be based solely on automated means. DSA, Article 20.

Certified out-of-court dispute settlement

For covered disputes, users also have the option of a certified out-of-court dispute settlement body. Before submitting a request, check the body's remit, the services and languages it covers, and any fee. Not every body is suitable for every case. Their decisions do not impose a binding settlement, and access to the courts remains available. Official list and rules on out-of-court dispute settlement.

Consider a hypothetical example: a post is removed and the user believes that the rule was applied incorrectly. A useful review request identifies the decision, the specific content and the reason for disagreeing. A general protest without these details makes the review more difficult.

What parents and minors should know

The protection of minors includes privacy, safety and risks arising from platform design. The Commission's guidelines address, among other matters, unwanted contact, bullying, harmful recommendations and features that encourage excessive use. They provide a framework for assessing and addressing risks, rather than a finding that Roblox or another of the three services has already breached every relevant rule. Guidelines on the protection of minors.

As a practical step, a parent can check with their child who can contact them, which information is public and how to report an incident. The regulatory development does not replace this check or require a family to wait until the compliance deadline before reporting a problem.

When to contact EETT

EETT, the Hellenic Telecommunications and Post Commission, has a complaint procedure for possible DSA infringements where the conditions it specifies for Greece are met. It examines, for example, whether the required reporting mechanisms work and whether the relevant obligations are being observed.

EETT itself explains that it does not decide whether content is illegal and does not resolve an individual disagreement with a decision restricting content or an account. A complaint about a missing or inadequate review system therefore differs from a request for a new decision on a particular post. EETT: complaints about intermediary digital services and limits of its remit.

Five elements of a useful request

The following practical list helps organise the file; it does not create an additional legal condition for bringing a challenge:

1. Identify the act: removal of a post, restriction of an account, rejection of a notice or another incident.
2. Keep the decision: the date you were informed, the reasons, the link and the reference number, where available.
3. Explain the disagreement precisely: identify the factual point or application of the rule that you consider incorrect.
4. Choose the appropriate procedure: platform review, a certified body or a regulatory compliance complaint, depending on the issue.
5. Limit attachments to what is necessary: avoid unrelated personal data and keep a copy of everything you submit.

The official overview of users' rights brings together the different options for reporting, challenging decisions and seeking judicial protection.

Frequently asked questions

Does designation mean that the services have been found illegal?

No. It places them in a category with additional obligations. A finding of an infringement and a penalty require a separate procedure.

Must I wait until 2027 to challenge a restriction?

There is no general requirement to wait. The rules already applicable, the service and the particular decision must be considered. Do not let a notified deadline pass.

Is a successful challenge guaranteed?

No. The outcome depends on the facts, the applicable rules and the remit of the procedure. The availability of a challenge does not predetermine the restoration of content or an account.

This article was prepared with artificial intelligence assistance and cross-checking of the cited official sources. It provides general legal information and does not replace assessment of a specific case. Sources checked: 9 September 2026.