Grand Theft Auto Online Title Updates past 1.16, which released on August 19, will require more storage space than the system can hold according to a Rockstar support page.
Since GTA Online and GTA V's Story Mode operate from the same install, players who don't wish to upgrade their hard drives but want to keep playing the story mode will have to do so without connecting to PlayStation Network.
PS3 storage can be replaced using an officially licensed kit or a standard 2.5" SATA hard drive. Consult Sony's official support page for more information on the upgrade process.
More than 34 million copies of Grand Theft Auto V have been shipped since the game released for PS3 and Xbox 360 in September 2013. It's planned for release on PC, PS4, and Xbox One this autumn.
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Source: http://www.computerandvideogames.com/475453/gta-online-updates-exceed-12gb-ps3-storage/
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