EU designates ChatGPT as a search engine under DSA

The European Commission said on Monday it has designated ChatGPT as a Very Large Online Search Engine (VLOSE) and Reddit and Roblox as Very Large Online Platforms (VLOPs) under Article 33 of the Digital Services Act, announced in press release IP/26/1772. Read this as a status change, not a penalty and not a finding of wrongdoing. The Commission's own designation register marks the decision for all three as "not yet available," so the legal texts that will spell out each obligation are not public yet, and IP/26/1772 carries no fine language.

ChatGPT is being treated as a search engine, not just a chatbot

The line that matters is the label on ChatGPT. The Commission classified it as a search engine, VLOSE, 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, after Google Search and Bing. 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, a threshold all three declared they cross: 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 line. "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.

What the designation actually adds

All three services 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). Hedge the exact month: 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, this is a schedule to build against, not a switch flipped today.

One question the two documents do not answer the same way

The supervisor for Reddit is genuinely 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. Do not assume that is resolved. It sits alongside a run of EU pressure on US platforms, from Google's site-reputation manual actions to the court ruling that unwound Anthropic's Pentagon blacklist.

The takeaway

If you run policy or compliance at one of the three, treat this as the trigger to stand up the VLOP or VLOSE tier now, not a fine to contest, since no fine was issued. The date that will actually govern you is a notification the Commission has not yet posted a decision text for, so calendar the four-month clock the moment each designation decision lands on the register, and do not treat the supervisor for Reddit as fixed until those texts say so.