Why did the EU classify ChatGPT as a search engine rather than a platform?

The European Commission describes ChatGPT as a "hybrid service" that meets the DSA definition of an online search engine because it engages with and responds to user prompts and queries, including by searching the web. Reddit and Roblox, which host user content instead, were designated Very Large Online Platforms in the same decision.

What data access do vetted researchers get from a designated service?

Under the DSA, a designated service such as ChatGPT must grant vetted researchers access to its data when the research helps detect and understand systemic risks in the EU. The Commission and national authorities also get data for monitoring. That turns a closed product into a studiable one for approved academic work.

What is the penalty if OpenAI misses the compliance deadline?

Non-compliance with the Digital Services Act can cost up to 6% of global annual turnover, according to Euronews. ChatGPT has four months from notification to meet the additional VLOSE duties, which include annual systemic risk assessments, an internal compliance function, and independent audits at least once a year.

Which other services were designated at the same time?

Reddit and Roblox were designated Very Large Online Platforms alongside ChatGPT. All three declared they reach at least 45 million average monthly users in the EU. Euronews puts Reddit at 57.2 million and Roblox at roughly 48 million, and reports the decision brings the total number of services in the DSA's strictest tier to 28.

European Commission · 2026-08-31 · major

ChatGPT is a search engine under EU law — DSA's strictest tier now applies

The European Commission designated ChatGPT a Very Large Online Search Engine under the Digital Services Act on August 31, 2026. It is the first generative AI chatbot placed in the DSA's strictest tier, and OpenAI has four months to comply.

EU flags outside the European Commission building in Brussels — Euronews

ChatGPT becomes the first generative AI chatbot to fall under the DSA's toughest rules.

Key specs

Chat gpt eu monthly users	159 million
Time to comply	4 months

Quick facts

Designated by	European Commission
Legal category	Very Large Online Search Engine
Law	Digital Services Act (DSA)
Designation threshold	45M average monthly EU users
Time to comply	4 months from notification
Maximum penalty	6% of global annual turnover
Also designated	Reddit and Roblox, as Very Large Online Platforms

What is it?

ChatGPT has been designated a Very Large Online Search Engine (VLOSE) under the EU's Digital Services Act. The European Commission announced the decision on August 31, 2026, alongside designations for Reddit and Roblox as Very Large Online Platforms. This is the first time a generative AI chatbot has landed in the DSA's strictest tier.

How does it work?

The Commission calls ChatGPT a "hybrid service" that qualifies as an online search engine because it can engage with and respond to users' prompts and queries, including by searching the web. Designation follows from scale: a service crosses the line at 45 million average monthly users in the EU. Euronews reports ChatGPT declared 159 million monthly active EU users for the six months ending March 2026.

Why does it matter?

The DSA's top tier brings real duties, not just a label. Designated services must run annual systemic risk assessments, submit to independent audits at least once a year, keep a public ad repository, offer a recommender option that is not based on profiling, and grant vetted researchers access to platform data for studying systemic risks. Penalties reach 6% of global annual turnover.

Who is it for?

policy teams, researchers studying AI systems, anyone shipping AI products in the EU

Frequently asked questions

Why did the EU classify ChatGPT as a search engine rather than a platform?: The European Commission describes ChatGPT as a "hybrid service" that meets the DSA definition of an online search engine because it engages with and responds to user prompts and queries, including by searching the web. Reddit and Roblox, which host user content instead, were designated Very Large Online Platforms in the same decision.
What data access do vetted researchers get from a designated service?: Under the DSA, a designated service such as ChatGPT must grant vetted researchers access to its data when the research helps detect and understand systemic risks in the EU. The Commission and national authorities also get data for monitoring. That turns a closed product into a studiable one for approved academic work.
What is the penalty if OpenAI misses the compliance deadline?: Non-compliance with the Digital Services Act can cost up to 6% of global annual turnover, according to Euronews. ChatGPT has four months from notification to meet the additional VLOSE duties, which include annual systemic risk assessments, an internal compliance function, and independent audits at least once a year.
Which other services were designated at the same time?: Reddit and Roblox were designated Very Large Online Platforms alongside ChatGPT. All three declared they reach at least 45 million average monthly users in the EU. Euronews puts Reddit at 57.2 million and Roblox at roughly 48 million, and reports the decision brings the total number of services in the DSA's strictest tier to 28.

Try it

https://digital-strategy.ec.europa.eu/en/policies/dsa-vlops