EU Classifies ChatGPT as Very Large Search Engine Under Digital Services Act

The European Commission expanded the reach of its flagship digital safety regime into generative artificial intelligence on Monday, formally designating ChatGPT as a Very Large Online Search Engine (VLOSE) under the Digital Services Act (DSA). In the same regulatory sweep, European authorities designated social discussion network Reddit and online gaming platform Roblox as Very Large Online Platforms (VLOPs), placing all three services under Brussels' most demanding tier of platform supervision^[1].

The move marks the first time a dedicated conversational AI system has been swept into the European Union's strictest tier of platform regulation. With the classifications taking immediate effect, OpenAI, Reddit, and Roblox have four months to bring their operations, algorithmic systems, and risk-mitigation measures into full compliance with the law or risk penalties that can reach up to 6 percent of their global annual turnover.

The Regulatory Calculus Behind the Search Classification

To qualify for the enhanced regulatory regime, online intermediaries must cross a statutory threshold of 45 million average monthly active users within the 27-nation bloc. While Reddit reported 57.2 million average monthly recipients and Roblox declared roughly 48 million, OpenAI submitted numbers confirming that ChatGPT Search reached approximately 159.1 million average monthly active users in the EU over the six-month period ending in March^[4].

The European Commission resolved a long-debated legal ambiguity by classifying ChatGPT as a search engine rather than a general hosting platform. European regulators determined that because the chatbot engages with user queries and searches the open web in real time to synthesize information, it qualifies as a hybrid service fitting the statutory definition of an online search engine under the DSA. That decision puts OpenAI alongside only two other designated search engines: Google Search and Microsoft Bing.

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.

Henna Virkkunen, European Commission Executive Vice-President for Tech Sovereignty, Security and Democracy

New Compliance Obligations and Direct Brussels Oversight

Under the DSA's enhanced tier, designated search engines and platforms must adhere to strict technical and operational mandates designed to protect public welfare and democratic discourse^[1]. OpenAI, Reddit, and Roblox now face several mandatory operational requirements:

• Systemic Risk Assessments: Conducting comprehensive analyses to identify and mitigate risks related to the dissemination of illegal content, negative impacts on minors, physical and mental well-being, and threats to electoral processes.
• Independent Annual Audits: Submitting platform algorithms, safety mechanisms, and mitigation architectures to external, independent auditors at least once per year.
• Data Access for Researchers: Providing vetted academic researchers and regulatory authorities with direct access to internal data to study systemic risks and safety compliance^[11].
• Advertising Repositories: Publishing public, searchable transparency archives documenting ad content, targeting parameters, and delivery metrics where advertising systems operate^[11].

The designations also establish a formal supervision structure. The European Commission will supervise compliance for ChatGPT and Reddit in direct coordination with Ireland's national media regulator, Coimisiún na Meán, where both companies maintain their primary European presence. Roblox will be supervised in conjunction with the Dutch Authority for Consumers and Markets.

A Shifting Legal Landscape for Fast-Growing Tech Services

With these three additions, the European Union's roster of designated very large online entities reaches 28 services, a group that already includes platforms operated by Meta, Apple, Amazon, ByteDance, and X. ^[12]The comparison below highlights how the latest batch fits into the DSA framework:

Enforcement of the Digital Services Act has already produced financial consequences across the technology sector. As reported by multiple outlets, European regulators have issued heavy penalties for DSA transparency and content violations over the past year, including fines against AliExpress, Temu, and Elon Musk's platform X.

Industry Reactions and Emerging Complexities

In response to the designations, the companies signaled cooperation with the European Commission. A spokesperson for OpenAI stated that ChatGPT Search operates as a search service under the DSA framework and that the company is actively preparing to fulfill the enhanced compliance obligations. Reddit representatives confirmed that the platform has prepared for the VLOP status and plans to coordinate closely with EU authorities, whil^[7]e Roblox expressed support for continued constructive engagement regarding its child-safety features.

Significant legal and technical questions remain regarding how search rules designed for traditional link aggregators will map onto generative AI models. Unlike conventional search indexes that retrieve published web pages, generative systems synthesize original responses, hallucinate facts, and generate conversational context dynamically. Evaluating systemic risk and algorithmic bias in real-time generative outputs represents uncharted territory for both OpenAI's engineering teams and Brussels regulators as the compliance deadline approaches.