EU designates ChatGPT a “Very Large Online Search Engine”
The Commission has put ChatGPT under the DSA’s VLOSE regime after the service reported at least 45 million average monthly EU users. The designation is about this service and its web-search role—not a blanket ruling that all AI is a search engine.
A new regulatory category applies
ChatGPT must meet the DSA’s additional requirements for very large online search engines, with compliance due by January 2027.
AI answers are now a regulated distribution surface
The focus shifts beyond model behavior alone to systemic risk from the service and its algorithms: illegal content, minors, wellbeing, fundamental rights, elections, and public security.
Revisit claims tied to public-facing AI
- Does your risk register cover search and answer-distribution behavior?
- Do safety, transparency, and incident evidence identify the deployed service—not only the model?
- Could customer-facing compliance answers need a new qualification?