On August 31, 2026, the European Commission formally designated ChatGPT a "Very Large Online Search Engine" (VLOSE) under the Digital Services Act, making it the first generative AI chatbot to receive this classification. Alongside Reddit and Roblox, it now faces the bloc's strictest rules.
OpenAI reported that ChatGPT had roughly 159.1 million average monthly active users in the EU during the six months ending March 31, 2026 — more than three times the 45-million threshold that triggers "very large" platform or search-engine designation under the DSA. The Commission concluded that a chatbot pulling live results from the internet functions, in regulatory terms, like a search engine: it described ChatGPT as a "hybrid service" that qualifies as an online search engine because it can interact with user queries, including by actively searching the web.
Services designated VLOSE (Very Large Online Search Engine) or VLOP (Very Large Online Platform) under the DSA have four months from notification to comply with the reinforced rules the regulation reserves for the largest-reach platforms: annual systemic risk assessments, independent audits, algorithmic transparency mechanisms, and specific content-moderation and minor-protection obligations. Reddit and Roblox simultaneously received "very large online platform" designation after also crossing the 45-million monthly EU user threshold.
This is the first time a major regulator has treated a generative AI chatbot under the same legal framework as Google Search or Bing. The Commission's reasoning — that a system answering queries using information retrieved from the web functions as a search engine regardless of its conversational interface — is a precedent other regulators (and likely the Commission itself, in future designations) can apply to Gemini, Copilot, or any assistant with live search capabilities and a similar scale of EU users.
Carlos Montiel is an enterprise AI solutions architect. He implements LLMs, Agents, RAG and orchestrators for companies across Guatemala and Latin America. Reach out for a consultation.
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