EU designates ChatGPT as a search engine under DSA

The European Commission has designated ChatGPT as a Very Large Online Search Engine, putting OpenAI's chatbot in the same Digital Services Act tier as Google Search and Bing.

Brussels said on Monday that Reddit and Roblox are Very Large Online Platforms under the same Article 33 rule. The announcement is press release IP/26/1772. The move is a status change, not a penalty and not a finding of wrongdoing. IP/26/1772 carries no fine language.

The Commission's own designation register still marks the decision for all three as "not yet available." The legal texts that will spell out each obligation are not public yet.

The label on ChatGPT is the part that matters. The Commission classified it as a search engine on the reasoning that it is a hybrid AI system that answers queries in part by searching the web, so it meets the DSA's definition of an online search engine rather than only a chatbot. That makes ChatGPT the third VLOSE the EU has ever named.

The register lists it under OpenAI Ireland Limited at 159.1 million average monthly EU users, against 364 million for Google Search and 119 million for Bing. The "very large" tier attaches above 45 million average monthly users in the bloc.

All three services said they cross that line: ChatGPT at 159.1 million, Reddit (as Reddit Netherlands B.V.) at 57.2 million, and Roblox at 46.6 million, only 1.6 million over the threshold. "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, in line with their large impact on our citizens and society," said Henna Virkkunen, the Commission's executive vice-president for tech sovereignty, security and democracy.

All three were already bound by the DSA's general platform and search duties. Designation adds the tier of obligations in Articles 34 to 43: an annual systemic risk assessment and mitigation, an independent audit, an ad repository, vetted-researcher data access, recommender-system transparency, and a standing compliance function. The Commission's risk themes span illegal content, protection of minors, user well-being, fundamental rights, civic discourse and elections, and public security.

The compliance clock is four months after notification under Article 33(6). The English release puts the deadline at January 2027, while the Commission's French and German pages say the end of December 2026. Either way, the switch is not flipped today.

The supervisor for Reddit is unsettled in the Commission's own paperwork. The press release routes ChatGPT and Reddit to Ireland's Coimisiún na Meán and Roblox to the Dutch ACM, while the register published the same day lists Reddit Netherlands B.V. and Roblox both under the Netherlands.

Both are Commission sources dated 31 August, and they disagree on who the Digital Services Coordinator for Reddit is. That fight sits alongside other EU pressure on US platforms, including Google's site-reputation manual actions. The designation is live. The decision texts, and Reddit's supervisor, are not.

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