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Roblox’s reported user numbers will make it subject to additional EU legislation for regulating social networks

Roblox’s reported user numbers could bring the platform under additional European Union requirements. The Roblox Digital Services Act designation is not yet confirmed, but the company has reported an average of 48 million monthly active users in the EU—above the law’s 45 million user threshold for very large online platforms.

Image credit: Roblox

Why the Roblox Digital Services Act threshold matters

The Digital Services Act (DSA) classifies online platforms and search engines with more than 45 million monthly users in the EU as very large online platforms (VLOPs) or very large online search engines (VLOSEs). Roblox reported that it averaged 48 million monthly active users in the region during the six months ending February 13, 2026.

That figure makes a VLOP designation possible, but it does not mean Roblox has already been formally designated. A European Commission spokesperson said the Commission is examining the reported figures and that a decision could come later. The spokesperson also noted that ChatGPT had announced user numbers above the same threshold.

For readers following the issue, the key distinction is between exceeding the user threshold and receiving an official designation. The latter is what would trigger the specific VLOP obligations.

What would change if Roblox became a VLOP?

If the Commission designates Roblox as a VLOP, the company would have to meet DSA requirements addressing systemic risks associated with its services. These include illegal content, the protection of minors, effects on mental and physical wellbeing, gender-based violence, and possible impacts on fundamental rights and public security.

After identifying and reporting relevant risks, the platform would need to take steps to reduce them. Depending on the risks involved, those measures could include changes to service design or recommendation systems, as well as additional internal resources for detecting and assessing problems.

Key requirements for very large platforms

VLOP obligations include several ongoing measures intended to support oversight and accountability:

  • Set up an internal compliance function to help ensure identified risks are mitigated.
  • Arrange an independent audit at least once a year and respond to its recommendations.
  • Share relevant data with the European Commission and national authorities for DSA monitoring.
  • Provide vetted researchers with access to platform data for research into systemic risks in the EU.
  • Offer a recommender-system option that does not rely on user profiling.
  • Maintain a publicly accessible repository of advertisements.

These requirements focus on how a large platform identifies risks, documents its response and allows regulators and approved researchers to assess its practices. Users and parents can watch for official announcements about any designation and for information from Roblox about changes to safety tools or recommendation settings.

When would the rules take effect?

Once a platform is formally designated as a VLOP or VLOSE, it has four months to comply with the DSA requirements. The designation may be revoked if the platform does not meet the user threshold for one full year.

The DSA and the Digital Markets Act were established in October 2022 and apply throughout the EU, including to companies based outside the region. Platforms that fail to comply can face penalties; in the most serious cases, fines may reach 6% of a company’s global turnover.

What to know about the Roblox Digital Services Act issue

Roblox’s reported 48 million monthly EU users exceed the 45 million threshold, making a VLOP designation possible. However, the European Commission has not confirmed that Roblox has been designated. If it does, the company would have four months to meet the relevant requirements, including risk assessments, independent audits, data access provisions and a non-profile-based recommendation option.

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