EU Designates ChatGPT as a Very Large Online Search Engine

What happened

On 31 August 2026, the European Commission designated OpenAI’s ChatGPT as a Very Large Online Search Engine (VLOSE) under the EU’s Digital Services Act — the first time a generative-AI chatbot has received that classification. The same decision placed Reddit and Roblox in the Very Large Online Platform (VLOP) category. The move was independently reported and confirmed by outlets not affiliated with the Commission or OpenAI.

Designation under this tier of the DSA triggers once a service reaches at least 45 million average monthly active users in the EU. OpenAI itself reported an average of about 159.1 million monthly active EU users for ChatGPT’s search function over the six months ending March 2026 — a figure OpenAI disclosed under DSA transparency rules, not one the Commission counted independently. Reddit and Roblox crossed the same threshold on their own numbers: Reddit reported about 57.2 million and Roblox roughly 46.6 to 48 million monthly active EU users, with figures varying slightly between outlets, both also self-reported.

Once designated, a VLOP or VLOSE has four months to comply with the DSA’s additional obligations for that tier. Applied to Monday’s designation, that puts the compliance deadline at the end of December 2026. Those obligations include annual systemic risk assessments covering illegal content, effects on minors, mental and physical well-being, fundamental rights, electoral processes and public security, plus independent annual audits, contact points for authorities, criminal-offence reporting, transparent terms and advertising disclosures, and data access for regulators and vetted researchers.

European Commission Executive Vice-President Henna Virkkunen said, “These new designations mean that ChatGPT, Reddit and Roblox will now be held to a higher standard of scrutiny and accountability in the European Union.”

According to Euronews, Ireland’s Coimisiún na Meán will supervise ChatGPT and Reddit, while the Netherlands’ ACM will supervise Roblox. Euronews also reports that this brings the total number of services designated under the DSA’s strictest tier to 28, with non-compliance penalties that can reach up to 6% of a company’s global annual turnover.

What this means (and what it does not)

For the Commission, the designation is evidence of the DSA reaching a high-profile AI product as debate over generative-AI regulation continues. For OpenAI, it means new compliance costs and scrutiny, triggered by a user figure the company reported itself and that the Commission’s published materials do not describe independently verifying. Reddit and Roblox face the same dynamic: their own self-reported figures are what brought them into the VLOP category.

What the designation does not establish is a bespoke regulatory regime for conversational AI. The Commission’s own policy page on VLOP/VLOSE obligations sets out no separate or different moderation requirements for search engines versus platforms — the two categories carry largely the same rules. This is the existing platform-oversight framework applied to a chatbot, not a purpose-built set of rules for how a conversational search product should behave. It also does not tell us what, if anything, a ChatGPT user in the EU will actually notice once compliance obligations take effect.

What we still do not know

No source describes whether VLOSE obligations — built for services with a traditional results page — will be technically adapted for a conversational product with no such interface, or simply applied unmodified. What end users will observe change, if anything, once the December 2026 deadline arrives is likewise not stated anywhere in this research.

It is not known whether other large language model providers — Google Gemini, Microsoft Copilot, Anthropic Claude, Meta AI — are near the 45-million-user threshold or under similar review; the Commission has not published comparable figures for them. Nor is it stated whether or how the Commission independently verified the self-reported user numbers behind these three designations before acting on them.

The claim that Ireland’s Coimisiún na Meán and the Netherlands’ ACM will supervise these services comes from a single outlet and was not confirmed on the Commission’s own designation page in this research. No statement or reaction from OpenAI, Reddit or Roblox was found, so whether any of the three intends to contest the classification is unknown. And the precise legal reasoning for classifying ChatGPT specifically as a “search engine” rather than a general online platform was not found sourced to a citable primary passage, despite appearing in secondary commentary.