Roblox may become the first game to be designated a very large online platform under European Union law, a status that would place it under the same obligations as the largest social networks and search engines.
GamesIndustry.biz, citing Gamesmarket, reports that Thomas Regnier, a spokesperson for the EU Commission for Tech Sovereignty, Defence and Space, described the designation as possible after Roblox disclosed user numbers above the Digital Services Act threshold.
We are not in the habit of prejudging potential future designations. 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.
The Digital Services Act sets the threshold for a very large online platform, or VLOP, at more than 45 million monthly users in the EU. In a submission earlier this year, Roblox confirmed an average of 48 million monthly active users in the territory over the six months ending February 13, 2026. GamesIndustry.biz reports it has approached Roblox for clarification.
What designation would require
A designated platform has four months to comply with the DSA, and the designation is revoked if the threshold goes unmet for a full year. Compliance begins with identifying and assessing systemic risks tied to the service, including illegal content, the protection of minors, mental and physical wellbeing, and gender-based violence.
Once those risks are reported to the Commission, the platform must act on them. The Commission's guidance describes this as adapting the design or functioning of a service, changing recommender systems, or adding internal resources to identify systemic risks. Roblox would also have to:
- Establish an internal compliance function to ensure identified risks are mitigated
- Submit to an independent audit at least once a year and act on its recommendations
- Share data with the Commission and national authorities so compliance can be monitored
- Give vetted researchers access to platform data for systemic-risk research
- Offer a recommender system option not based on user profiling
- Maintain a publicly available repository of advertisements
Penalties
The DSA and the Digital Markets Act were established in October 2022 and apply across the EU, including to companies based outside the region. Firms that fail to comply face penalties reaching, in the most serious cases, 6% of global turnover.
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