Short Answer: Why did the EU designate ChatGPT a “very large online search engine”?
The European Commission designated ChatGPT a “very large online search engine” (VLOSE) under the EU Digital Services Act on August 31, 2026 — the first time an AI chatbot has received the label. OpenAI’s own DSA disclosure put ChatGPT search at roughly 159.1 million average monthly active recipients in the EU, more than three times the 45-million threshold that triggers the designation.
Quick Summary
- The Commission designated ChatGPT a very large online search engine because it “responds to users’ prompts and queries, including by searching the web.”
- Reddit and Roblox were designated very large online platforms the same day, each reporting well above the 45-million EU user threshold.
- All three services have four months from notification to meet added DSA obligations: systemic-risk assessments, annual independent audits, regulator and researcher data access, and (where applicable) a non-profiling recommender option and a public ad archive.
- Designation is not a finding of wrongdoing — enforcement is separate, and DSA fines can reach 6% of a company’s global annual revenue.
- The decision follows the EU’s separate DMA order forcing Google to share search data with qualifying rivals, extending regulatory scrutiny to AI answer engines specifically.
Search Engine Journal first reported the designation, based on the European Commission’s announcement and OpenAI’s own DSA disclosure.
What did the European Commission actually decide?
On August 31, the European Commission designated ChatGPT a “very large online search engine” under the Digital Services Act — the first time the label has been applied to an AI chatbot. The Commission made two other designations the same day: Reddit and Roblox are now recognized as “very large online platforms,” the DSA’s equivalent category for non-search services.
The threshold for either label is the same: at least 45 million average monthly active recipients in the EU. OpenAI’s own disclosure put ChatGPT search at approximately 159.1 million average monthly active recipients over the six months ending March 31, 2026 — more than three times the threshold. Reddit reported no more than 57.2 million monthly users for the first half of 2026, and Roblox estimated its average at 46.6 million.
Why does ChatGPT count as a search engine at all?
The Commission described ChatGPT as a hybrid service that qualifies as an online search engine specifically because it responds to user prompts and queries, including by searching the web. That framing matters: it treats retrieval-and-answer behavior, not a traditional results page, as what makes something a search engine under EU law.
Henna Virkkunen, the Commission’s executive vice-president for tech sovereignty, security and democracy, said the designations mean the three services will be “held to a higher standard of scrutiny and accountability” in the EU, given their reach.
What do ChatGPT, Reddit, and Roblox now have to do?
All three services have four months from notification to meet the DSA’s additional obligations for its largest platforms and search engines:
- Systemic-risk controls: identify, assess, and mitigate risks tied to the service and its algorithmic systems, including illegal content, harm to minors, effects on mental and physical wellbeing, fundamental rights, electoral processes, and public security.
- Independent audits: undergo an outside audit at least once a year and respond to the auditor’s recommendations.
- Regulator and researcher access: share data with the Commission and national authorities, and give vetted researchers access for qualifying systemic-risk research.
- Recommenders and ads: where applicable, offer a recommender option that isn’t based on profiling, and maintain a public archive of ads shown on the service.
Designation is not a finding of wrongdoing, and enforcement runs as a separate process. If a service is later found to have broken DSA rules, fines can reach as much as 6% of the company’s global annual revenue. The Commission has already levied a combined €870 million in DSA fines to date, including €550 million against AliExpress in July. If a designated service stays below the 45-million threshold for a full year, the Commission can revoke the designation.
How does this connect to the EU’s case against Google?
This designation extends a separate thread the Commission has been pulling on all year. Under the EU’s Digital Markets Act, a binding order that took effect in July requires Google to share search data with qualifying rivals — and chatbots with search functions can request access if they meet the DMA’s own definition of an online search engine. The DMA and DSA are different laws with different tests, but today’s decision goes a step further: it designates ChatGPT itself as a very large online search engine, not just a potential recipient of Google’s data.
Why does this matter for AEO and brand marketing?
For a publication built around the premise that AI answer engines are the new search, this is the first time a regulator has said so in exactly those terms — officially, in a binding legal designation, not a trend piece. That has practical downstream effects. The transparency obligations attached to VLOSE status, especially regulator and vetted-researcher access to platform data, create a legal channel for studying how ChatGPT search actually surfaces and weighs sources, a question AEO practitioners have mostly had to reverse-engineer through prompt testing. See our breakdown of how ChatGPT chooses sources for what’s currently known without that data.
The public ad-archive requirement is also worth watching alongside ChatGPT’s ongoing ads rollout in Europe — it means any advertising OpenAI runs in the EU will be more visible to competitors and researchers than typical platform ad data usually is.
And it’s worth noting who else got named alongside ChatGPT: Reddit, which lost the large majority of its ChatGPT citations earlier this year, is now a designated very large online platform in its own right. Two of the biggest names in AI search’s source ecosystem are now under the same regulatory microscope, for different reasons, at the same time.
Frequently Asked Questions
What is a “very large online search engine” under the DSA?
It’s a European Commission designation under the Digital Services Act for search engines with at least 45 million average monthly active recipients in the EU. It carries added obligations around systemic-risk management, independent audits, and regulator and researcher data access.
Is ChatGPT the first AI chatbot designated this way?
Yes. The Commission’s August 31 decision is the first time it has applied the very large online search engine designation to an AI chatbot.
How many EU users does ChatGPT search have, according to OpenAI?
OpenAI’s DSA disclosure reported approximately 159.1 million average monthly active recipients for ChatGPT search in the EU, for the six months ending March 31, 2026.
Does this designation mean ChatGPT broke the rules?
No. Designation is a classification based on user numbers and service type, not a finding of wrongdoing. Enforcement for any rule violations is a separate process, with fines that can reach up to 6% of a company’s global annual revenue.
What do ChatGPT, Reddit, and Roblox have to do now?
Within four months of notification, each must implement systemic-risk assessments, undergo an annual independent audit, provide data access to regulators and vetted researchers, and, where applicable, offer a non-profiling recommender option and maintain a public ad archive.
Source: Search Engine Journal.
About the author
Kai Williams
Kai Williams has been in marketing for years, with a long background in SEO before AEO had a name. He stepped into Answer Engine Optimization the moment AI started reshaping how people search, and has been tracking the shift ever since. At Prompt Insider, he covers AEO, AI marketing, and the future of search, breaking down what is changing and what brands need to do about it.
