EU designates ChatGPT a very large online search engine under the Digital Services Act

The European Commission designated ChatGPT a Very Large Online Search Engine (VLOSE) under the Digital Services Act — the first time an AI chatbot has been placed in that category. The Commission classified ChatGPT as a hybrid service that qualifies as a search engine because it answers user prompts partly by searching the web. Reddit and Roblox were designated the same day as Very Large Online Platforms, the DSA’s parallel category for social and gaming services.

The threshold for either designation is 45 million average monthly users in the EU; OpenAI had declared that ChatGPT reached roughly 159.1 million over the six months to 31 March 2026, more than three times that figure. Designation as a VLOSE or VLOP triggers the DSA’s heaviest obligations: providers must assess and mitigate “systemic risks” that include the spread of illegal content, harm to minors, effects on users’ mental and physical well-being, threats to fundamental rights, and risks to electoral processes and public security, and they must submit to independent audits and give regulators and vetted researchers access to their data. OpenAI has four months from notification — until January 2027 — to bring ChatGPT into compliance; non-compliance under the DSA’s general enforcement regime can draw fines of up to 6% of a company’s global annual turnover.

The designation extends a regulatory framework built for search engines and social platforms to a conversational AI product for the first time, and sets a concrete date by which OpenAI must show its risk-assessment and transparency processes meet EU standards rather than voluntary company commitments. It arrived as the EU AI Act’s own compliance deadlines were being pushed back under a separate simplification package, making the DSA — a pre-existing law originally aimed at platforms rather than AI models — the more immediate lever the bloc had for reaching a chatbot’s behaviour toward EU users, including minors.