EU designates ChatGPT as very large search engine

The European Commission on August 31 designated OpenAI’s ChatGPT as a Very Large Online Search Engine under the Digital Services Act, extending the bloc’s toughest platform rules to a mass-market generative AI service. The designation places ChatGPT in the same DSA tier as the largest search services, with direct Commission supervision and added duties on risk assessment, mitigation, audits and transparency. (digital-strategy.ec.europa.eu) Reddit and Roblox were designated the same day as Very Large Online Platforms, according to the Commission. (help.openai.com) OpenAI’s own EU disclosure appears to have supplied the key threshold number. The company said ChatGPT search had about 159.1 million average monthly active recipients in the European Union during the six months ending March 31, 2026, well above the DSA trigger of 45 million monthly users for very large services. (digital-strategy.ec.europa.eu) ### Why did Brussels classify ChatGPT as a search engine? The Commission said on August 31 that it had designated ChatGPT specifically as a Very Large Online Search Engine, or VLOSE, under the DSA. The law applies that label to services meeting the user threshold and carrying search-engine obligations under the regulation’s framework. (digital-strategy.ec.europa.eu) OpenAI’s help-center disclosure refers to “ChatGPT search” rather than the chatbot as a whole. That disclosure says the 159.1 million figure was calculated for DSA compliance purposes for the period ending March 31, 2026. ### What changes for OpenAI after the designation? (help.openai.com) Under the Commission’s DSA rules for very large platforms and search engines, a newly designated service has four months to comply. Those obligations include assessing and mitigating systemic risks, undergoing independent audits, maintaining crisis-response and transparency processes, and facing direct oversight by the Commission. The DSA allows penalties of up to 6% of a company’s worldwide annual turnover for infringements, according to the Commission’s DSA materials. (digital-strategy.ec.europa.eu) The Commission has used formal requests for information and other enforcement tools against previously designated services. (help.openai.com) ### Is this separate from the EU AI Act? The AI Act and the DSA are separate regimes, and both now touch OpenAI’s products in Europe. The Commission said on July 31 that, from August 2, 2026, its AI Office and national authorities would begin enforcing AI Act rules and new transparency requirements. (digital-strategy.ec.europa.eu) The AI Act materials focus on obligations for general-purpose AI models and certain AI systems, while the DSA materials focus on online intermediaries, platforms and search engines. In practice, that means OpenAI can face one set of duties tied to the operation of ChatGPT as a large search-like service and another tied to AI-specific rules. (digital-strategy.ec.europa.eu) ### Why does Reddit and Roblox matter here? Reddit and Roblox were designated on the same day as Very Large Online Platforms, the Commission said. Their inclusion shows the August 31 action was part of a broader update to the DSA’s list of directly supervised services, not a standalone move aimed only at OpenAI. (digital-strategy.ec.europa.eu) The Commission’s supervision page lists designated VLOPs and VLOSEs under the DSA and says it oversees compliance for those services. That list already included major search and platform operators before the addition of ChatGPT, Reddit and Roblox. (digital-strategy.ec.europa.eu) ### What happens next, and when? The four-month compliance window means OpenAI must meet the VLOSE obligations by the end of December 2026, based on the Commission’s August 31 designation date. The Commission’s DSA supervision page and OpenAI’s DSA transparency materials are the main public sources for the next disclosures and any follow-up enforcement steps. (digital-strategy.ec.europa.eu 1) (digital-strategy.ec.europa.eu 2)