EU Designates ChatGPT as a Very Large Online Search Engine Under DSA

The European Commission has officially designated OpenAI's ChatGPT as a Very Large Online Search Engine (VLOSE) under the Digital Services Act, the first generative AI chatbot to receive that classification. Reddit and Roblox were designated as Very Large Online Platforms in the same decision, bringing the total number of designated services under the DSA to 28.

Why the Designation Matters

Crossing 45 million monthly users, about one in ten people in the EU, is the statutory trigger for enhanced supervision. OpenAI reported approximately 159.1 million average monthly recipients for ChatGPT search, well above the threshold.

The Commission resolved the ambiguity by calling ChatGPT a hybrid service — one that, because it responds to user queries including by actively searching the web, functions enough like a search engine to warrant the search-engine designation. That puts it in a very small club: ChatGPT is now one of only three services designated as a Very Large Online Search Engine under the DSA, alongside Microsoft Bing and Google Search.

What OpenAI Has to Do Now

Following notification, they have four months, until the end of January 2027, to assess and mitigate systemic risks from their services and algorithmic systems. Those assessments must cover illegal content, harm to minors, users' physical and mental well-being, fundamental rights, electoral processes and public security.

ChatGPT must also undergo an independent audit at least once a year and respond to the auditor's recommendations, share data with the Commission and national authorities, and allow vetted researchers access for qualifying systemic-risk research.

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The Regulatory Backdrop

The Digital Services Act, passed in 2022, sets rules for large online services to protect users from illegal and harmful content. But it was written before generative AI went fully mainstream and did not clearly spell out how AI services like ChatGPT should be classified.

The designation also gives the European Commission greater authority to oversee and investigate the services. Designation is not a finding of wrongdoing. Enforcement is a separate process, but the compliance overhead is real.

Options market and stocks to watch

Watch for compliance-cost and headline risk to bleed into several names tied to this decision:

• MSFT: OpenAI's largest backer and Bing operator — watch for read-through on AI regulatory exposure across Microsoft's stack.
• GOOGL: Google Search is already a VLOSE, and Gemini could face similar scrutiny. Watch for reaction in EU-linked ad and search revenue commentary.
• RDDT: Reddit was designated a VLOP in the same announcement. Watch for guidance on compliance costs and moderation spend.
• RBLX: Roblox also picked up the VLOP tag, with heightened child-safety obligations. Watch for options flow around any EU exposure updates.
• META: Already carrying multiple VLOP designations — watch how this precedent shapes the broader EU AI enforcement path.

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