The European Commission on August 31 designated ChatGPT as a Very Large Online Search Engine (VLOSE) under the Digital Services Act, alongside separate Very Large Online Platform (VLOP) designations for Reddit and Roblox. The move places ChatGPT under a heavier EU compliance regime than it previously faced as a general-purpose AI product.

Why ChatGPT qualifies

The DSA's VLOSE and VLOP categories apply to services that report at least 45 million average monthly users in the EU. OpenAI disclosed roughly 159.1 million average monthly ChatGPT users in the bloc, well above that threshold. The Commission's reasoning turned specifically on ChatGPT's web-search capability: because the chatbot can search the live web and surface results in response to user prompts, the Commission classified it as a "hybrid" service that qualifies as an online search engine under the DSA's definition, rather than regulating it purely as a generative-AI tool. A spokesperson for OpenAI said the company is "preparing to meet the additional compliance requirements that come with this Very Large Online Search Engine designation."

New obligations, January 2027 deadline

The designation gives OpenAI four months to comply, setting a deadline of January 2027. The added obligations include identifying, assessing and mitigating systemic risks tied to the service and its algorithmic systems, undergoing independent audits at least once a year, and sharing data with the European Commission and national regulators on request. VLOSE status also brings additional transparency requirements around how search results and rankings are generated.

Why it matters

The designation is the first time EU regulators have applied "search engine" obligations, rather than pure AI-product rules, to a chatbot — and the Commission explicitly grounded the decision in ChatGPT's web-search function rather than its underlying model. That creates a capability-based template regulators can extend to other assistants with live web access, including Google's Gemini, Anthropic's Claude and Perplexity, as those products scale up in the EU. For OpenAI, it adds a second, overlapping compliance track alongside the obligations it already carries as a general-purpose AI model provider under the EU AI Act, ahead of a compliance deadline that arrives early in 2027.