The European Commission designated ChatGPT as a very large online search engine under the Digital Services Act, placing OpenAI's chatbot in the same regulatory tier the bloc built for Google Search and Bing.
Reddit and Roblox were designated very large online platforms, or VLOPs, the DSA tier for services that host and rank the content their users post. ChatGPT went into a separate category, that of a very large online search engine, or VLOSE. The European Commission judged that its browsing feature works like a search tool, answering open-ended queries by drawing on material from across the web, which is the test it applies to Google Search and Bing. Reddit and Roblox instead fall under the platform obligations that already cover Facebook, TikTok, and YouTube.
According to the European Commission, all three companies had declared that they reach at least 45 million average monthly users in the European Union, the level that triggers designation. They now have four months, until January 2027, to meet the additional duties the DSA places on its largest services: identifying and reducing systemic risks tied to illegal content, harm to minors, users' physical and mental health, fundamental rights, elections, and public security.
For OpenAI, the status brings requirements the ChatGPT product has not carried before. The company will have to commission an independent annual audit of its risk controls, open internal data to vetted researchers, publish regular transparency reports on how it handles content, and document the way its systems rank and recommend information. The European Commission also takes on direct oversight of the search feature, backed by fines that can reach 6 percent of a company's global annual revenue.
The decision pulls generative AI into the DSA for the first time. The law's roster of very large platforms and search engines already spans around two dozen services, and the European Commission has opened formal proceedings against several of them, including X and TikTok, over content and transparency rules. OpenAI already answers to the separate EU AI Act, so the designation stacks a second compliance regime on the ChatGPT search product. The rules on protecting minors are likely to weigh most on Roblox, whose audience skews toward children and teenagers.
The unsettled question is whether a framework written for link-based search fits a system that composes answers rather than listing sources. OpenAI's first systemic risk assessment, due by January, will show how much the Commission expects a chatbot to disclose about the risks its output creates, and how far it must go to contain them.
