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On August 31, the European Commission formally designated ChatGPT a Very Large Online Search Engine, or VLOSE, under the Digital Services Act.
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Reddit and Roblox were designated in the same action, but as Very Large Online Platforms, or VLOPs.
The distinction is easy to overlook. It may also be the most interesting part of the announcement.
In explaining its decision, the Commission points to what ChatGPT actually does. The service can engage with and respond to users’ prompts and queries, including by searching the web.
The Commission describes ChatGPT as a “hybrid service” and says that it therefore qualifies as an online search engine under the DSA.
That places ChatGPT in a different legal category from Reddit and Roblox, which the Commission classified as online platforms.
The designation is not, by itself, a finding that ChatGPT violated the Digital Services Act. It places the service within a regulatory category that carries additional obligations because of its function and scale.
Under the DSA, a service can be designated very large when it reaches at least 45 million average monthly active recipients in the European Union.
ChatGPT search is well above that threshold.
OpenAI reported approximately 159.1 million average monthly active recipients in the EU for ChatGPT’s online search features during the six-month period ending March 31, 2026.
That number requires an important qualification.
OpenAI says the figure was calculated specifically for its obligations under the DSA and applies to ChatGPT’s online search features. It should not be treated as a general measure of how many people use ChatGPT.
That distinction matters because the Commission’s explanation for placing ChatGPT in the search-engine category rests on the service’s ability to search the web.
Once designated, ChatGPT becomes subject to the additional obligations the DSA imposes on its largest services.
Those obligations include assessing and mitigating systemic risks associated with a service and its algorithmic systems. The law addresses risks involving illegal content, fundamental rights, electoral processes, public security, minors, and users’ physical and mental well-being, among other areas.
Under the DSA, those additional obligations apply four months after notification of the designation.
That establishes the regulatory timetable.
It does not yet tell us exactly what compliance will look like inside ChatGPT.
The Commission has provided a basic explanation for the classification, but its full designation decision is not yet publicly available. The Commission’s own registry lists ChatGPT’s August 31 designation while noting that the underlying decision has not yet been published.
That leaves consequential questions unanswered.
ChatGPT can search the web, but search is only one part of the product. It can also generate answers, analyze documents, write code, create content and perform other tasks within the same interface.
The public material does not yet explain in detail how the Commission will draw boundaries among those functions when applying the DSA’s additional obligations.
The legal framework is not entirely unprepared for that overlap. The European Union’s AI Act already recognizes that an online chatbot capable of searching the web can fall within the definition of an online search engine under the DSA.
But identifying the category is different from showing how the rules will operate inside the product.
That is what makes this designation significant.
The Commission has answered one question: for purposes of the Digital Services Act, ChatGPT qualifies as an online search engine, and its scale places it in the very large category.
The harder question comes next.
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How far do the obligations attached to that category reach inside a service where searching the web, generating an answer and performing other AI-driven tasks can happen within the same conversation?
A clearer answer should emerge when the Commission publishes its full designation decision and as OpenAI begins demonstrating how it will comply with the additional requirements.
For now, the most important development is not simply that Europe has placed another major technology service under stricter oversight.
It is that one of the world’s most prominent generative AI systems now sits formally inside the regulatory category of an online search engine.
The label is settled.
What that label ultimately reaches is not.
Sources
Thabk you for reading,
Neon