ChatGPT Becomes an EU Search Engine—and Gets Four Months to Comply

In an August 31, 2026 designation notice, the European Commission classified ChatGPT as a Very Large Online Search Engine, or VLOSE, after the service declared at least 45 million average monthly users in the European Union; OpenAI now has four months, described as running to January 2027, to meet the additional Digital Services Act obligations.

The classification rests on both ChatGPT’s scale and its ability to search the web in response to users’ prompts. It does not establish that OpenAI has violated the DSA or turn every generative AI product into a regulated search engine, but it places ChatGPT in the law’s enhanced tier for services whose reach can create systemic risks across the EU.

What the Commission designated

The designation applies to ChatGPT as a VLOSE. Reddit and Roblox entered the same scale-based regulatory tier as Very Large Online Platforms, or VLOPs, but their legal category differs because those services are treated as platforms rather than search engines.

That distinction limits the scope of the decision. ChatGPT is covered because the Commission considers its combination of conversational responses and web search to satisfy the DSA definition of an online search engine. The decision does not classify generative AI as a whole, and it is separate from any finding that a particular ChatGPT answer or feature breaches EU law.

The designation also settles the earlier uncertainty around ChatGPT’s EU audience size and its possible regulatory status. The relevant sequence point was not whether ChatGPT resembled a conventional page of ranked links, but whether its search-supported service fell within the legal definition and met the audience threshold.

Why ChatGPT qualifies as a search engine

The functional test comes first. ChatGPT accepts prompts and queries, can search online material and returns information related to the requested subject. Under the DSA approach described in the decision, the conversational format of the result does not prevent the service from qualifying as an online search engine.

TechRadar’s September 1 account similarly explains that the Commission treated ChatGPT’s web-search functionality as part of the search market, while retaining the separate VLOP classifications for Reddit and Roblox.

Scale supplies the second part of the test. An online search engine becomes eligible for VLOSE designation when it reaches at least 45 million average monthly active recipients in the EU. Audience size alone is therefore insufficient: a service must first qualify as an online search engine and then meet or exceed the statutory reach threshold.

What the four-month window requires

The four months are a transition period for meeting the obligations attached to VLOSE status, not a trial period for the designation. The Commission expressed the endpoint as January 2027 without publishing a more precise calendar date in its public notice, so the operative timing depends on notification of the designation to the provider.

The central additional duty is to identify, analyse and assess systemic risks in the EU arising from ChatGPT’s design, operation, algorithmic systems and use. The areas named for review include dissemination of illegal content, negative effects on minors, users’ physical and mental well-being, fundamental rights, electoral processes and public security. OpenAI must adopt measures that are reasonable, proportionate and effective for the risks it identifies.

The enhanced regime also brings organisational and scrutiny requirements. A September 1 legal analysis by Pinsent Masons identifies enhanced transparency duties, an independent compliance function for the covered service, annual independent audits and potential disclosure of data to the European Commission or Ireland’s Media Commission.

These mechanisms are intended to give regulators and auditors evidence for evaluating OpenAI’s assessment and mitigation work. The designation itself does not order a specific interface redesign, remove a ChatGPT feature or decide the legality of individual search-supported answers.

What changes for users and operators

Users may see no immediate product change during the transition period. The first effects are more likely to occur inside OpenAI’s governance, risk controls, audit preparation and transparency processes, followed by any service changes the company considers necessary to mitigate identified EU-wide risks.

The decision designates ChatGPT and places the resulting obligations on the provider of that service. It does not automatically classify a business or developer as a VLOSE merely because it uses or integrates ChatGPT. Such operators may still have separate duties under the DSA or other EU rules, depending on the structure and function of their own services.

The compliance timeline is therefore straightforward: designation on August 31, 2026, following satisfaction of the search-engine and audience tests; a four-month implementation period; and application of the additional VLOSE duties by January 2027. What remains unknown is which specific mitigation or product measures OpenAI will adopt and how EU supervisors will assess them once the transition period ends.

Also read:

• ChatGPT Search Reaches 159.1 Million in EU — Still No VLOSE Label
• Reasons to Use A People Search Engine
• Everything You Need to Know about Search Engine Scraping