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Roblox could become the first game to be classified as a very large online platform (VLOP) under European legislation.
As noted by Gamesmarket, Thomas Regnier, a spokesperson for the EU Commission for Tech Sovereignty, Defence, and Space, recently suggested that this designation is “definitely possible” after Roblox announced user numbers above the threshold of the Digital Services Act (DSA).
VLOPs and very large online search engines (VLOSEs) are classified as such if they reach over 45 million monthly users in the EU.
The firm confirmed in a submission earlier this year that it reached an average of 48 million monthly active users in the territory for the six months ending February 13, 2026.
“We are not in the habit of prejudging potential future designations,” said Regnier. “But I can confirm, however, that both ChatGPT and Roblox have indeed announced user numbers above the DSA threshold. So designation is definitely possible, could come sooner or later, and the Commission is definitely looking into these numbers for a potential future designation.”
GamesIndustry.biz has reached out to Roblox for further clarification.
If Roblox is classified as a VLOP, it must comply with the DSA and specific rules addressing the risks of illegal content and its “impact on fundamental rights, public security, and wellbeing.”
Once a platform is designated as a VLOP or VLOSE, it has four months to comply with the DSA. The decision will be revoked if the threshold is not met during one full year.
As a VLOP, Roblox would have to “identify, analyse, and assess systemic risks that are linked to their services”, including illegal content, protection of minors, mental and physical well-being, and gender-based violence, among others.
Once risks are identified and reported to the EU Commission, Roblox would need to implement measures to address them.
As the EU Commission states: “This could mean adapting the design or functioning of their services or changing their recommender systems. They could also consist of reinforcing the platform internally with more resources to better identify systemic risks.”
It would also have to:
- Establish an internal compliance function that ensures that the risks identified are mitigated
- Be audited by an independent auditor at least once a year and adopt measures that respond to the auditor’s recommendations
- Share their data with the Commission and national authorities so that they can Monitor and assess compliance with the DSA
- Allow vetted researchers to access platform data when the research contributes to the detection, identification and understanding of systemic risks in the EU
- Provide an option in their recommender systems that is not based on user profiling
- Have a publicly available repository of advertisements
The DSA and the Digital Markets Act were established in October 2022. Both acts are applicable across the whole of the EU, including companies not based in the region.
Companies and platforms affected by the DSA that do not comply will face penalties. In the most serious cases, firms will be fined up to 6% of their global turnover.
