EU tags ChatGPT a very large search engine under the DSA

BRUSSELS — On Aug. 31, 2026, the European Commission designated ChatGPT a Very Large Online Search Engine (VLOSE) and Reddit and Roblox Very Large Online Platforms (VLOPs) under the Digital Services Act. The designations are the rule. The clock is four months from notification — compliance by January 2027.

Each service declared at least 45 million average monthly users in the EU, the DSA threshold for the enhanced regime. That is the scale test. The Commission did not find a violation. It classified the services.

The rule in English

VLOPs and VLOSEs must assess and mitigate systemic risks from their services and algorithmic systems. The Commission’s list includes illegal content, negative effects on minors, users’ physical and mental well-being, fundamental rights, electoral processes, and public security. Independent audits and transparency reporting follow the same clock.

ChatGPT is the novel call. The Commission calls it a hybrid AI system that answers prompts “including by searching the web,” and therefore an online search engine under the DSA. Reddit is a discussion platform. Roblox is a user-generated gaming and creation platform. Both qualify as online platforms because users disseminate third-party content to the public.

Who wrote it / who it binds

The writer is the European Commission, acting under the DSA’s designation power. The bound parties are the providers of ChatGPT (OpenAI’s EU establishment), Reddit, and Roblox.

Supervision splits by establishment: Coimisiún na Meán (Ireland) for ChatGPT; the Netherlands Authority for Consumers and Markets (ACM) for Reddit and Roblox. The Commission gains investigative powers over the designated services’ functionalities and related systems.

Who it exempts

Services under 45 million average monthly EU users stay outside this designation class. The Aug. 31 notice does not rewrite the DSA for smaller platforms. Direct-message carve-outs and product-specific exemptions are not the story here; this is classification and clock, not a finished audit.

What changes for a founder, parent, or worker

Founders shipping conversational AI that retrieves and synthesizes the open web should treat EU search-engine classification as live precedent, not a ChatGPT-only quirk. Parents and schools get a regulatory hook: designated services must document and mitigate risks to minors. Workers in trust-and-safety and model policy now write to a January 2027 audit calendar, not a voluntary code.