The EU officially designates ChatGPT as a 'super-large-scale online search engine,' requiring OpenAI to implement additional measures such as risk assessment and independent audits.

On August 31, 2026, the European Commission officially designated OpenAI's ChatGPT as a 'Very Large Online Search Engine (VLOSE)' under the Digital Services Act (DSA). ChatGPT falls into the strictest regulatory category of the DSA, which applies to services used by more than 45 million people per month in the EU. This means OpenAI will be subject to additional obligations, such as assessing and mitigating the risks its service poses to society. At the same time, Reddit and Roblox were also designated as 'Very Large Online Platforms (VLOP).'

Commission designates ChatGPT, Reddit, Roblox under Digital Services Act | Shaping Europe's digital future
https://digital-strategy.ec.europa.eu/en/news/commission-designates-chatgpt-reddit-roblox-under-digital-services-act

The DSA is a law that governs online services provided within the EU, covering issues such as combating illegal content, protecting users, and ensuring transparency in advertising and content recommendations. In particular, online platforms and search engines with more than 45 million monthly users in the EU are designated as VLOP or VLOSE, and additional rules apply that take into account the impact of the service's scale on society as a whole.

Because ChatGPT can answer user questions and also perform web searches, the European Commission classified ChatGPT as a 'hybrid service' and determined that it qualifies as an online search engine on the DSA.

OpenAI has already prepared contact points for authorities and users, means for reporting illegal content, and transparency information in response to the DSA, but this VLOSE designation means that the scope of its obligations has expanded to include additional obligations that only apply to large services.

According to figures released by OpenAI for DSA compliance , the average monthly active recipients in the EU using ChatGPT's online search function during the six months leading up to March 31, 2026, were approximately 159.1 million. This number is more than three times the 45 million threshold for VLOSE designation under DSA, which led to the VLOSE designation.

ChatGPT and Roblox surpass 45 million monthly users in the EU, to be designated as 'mega-platforms' - GIGAZINE

Being designated as VLOSE means that OpenAI must assess the 'systemic risks' arising from the ChatGPT service and algorithms within the next four months and take necessary measures. These systemic risks include 'spread of illegal content,' 'impact on minors,' 'the mental and physical health of users,' 'fundamental rights such as freedom of expression and privacy,' 'election processes,' and 'public safety.' Furthermore, VLOSE requires at least one independent audit per year, data provision to authorities, and data provision to reviewed researchers.

The European Commission, in cooperation with national digital services coordinating bodies, will oversee compliance with the additional obligations, and if a DSA violation is found, a fine of up to 6% of the company's global annual turnover may be imposed, depending on the severity and duration of the violation.

Simultaneously with ChatGPT's VLOSE designation, Reddit and Roblox were designated as Very Large Online Platforms (VLOPs). Henna Vilkkunen, Senior Vice-President of the European Commission for Technology Sovereignty, Security and Democracy, explained that this designation means ChatGPT, Reddit, and Roblox will be required to have 'higher levels of oversight and accountability' within the EU. The European Commission also stated that it will continue to monitor developments in digital services and will continue to designate services that meet the enhanced supervisory standards.