ChatGPT Becomes the First AI Chatbot Labeled a Very Large Search Engine Under EU Rules

ChatGPT is now a search engine in the eyes of EU law, and a very large one. The European Commission on Monday designated OpenAI’s chatbot a Very Large Online Search Engine under the Digital Services Act, the first AI chatbot to land in the law’s strictest tier, and named Reddit and Roblox Very Large Online Platforms.

All three told the Commission they reach at least 45 million average monthly users in the EU, the threshold for the extra rules. The Commission’s announcement explains why ChatGPT counts as a search engine rather than a platform: it is an AI system that responds to users’ prompts and queries, “including by searching the web,” which makes it “a hybrid service that qualifies as an online search engine under the DSA.” Politico reported that Brussels had struggled with that question since OpenAI declared 120 million EU users last year.

Four months to comply

The services have until January 2027 to meet the additional obligations. Chief among them is assessing and mitigating systemic risks from their services and algorithms, covering the spread of illegal content, effects on minors, users’ physical and mental well-being, fundamental rights, electoral processes and public security. Failing to comply can bring fines of up to 6% of global annual revenue.

The Commission will supervise the companies directly, working with Ireland’s Coimisiún na Meán on ChatGPT and the Dutch Authority for Consumers and Markets on Reddit and Roblox. The designations bring the DSA’s list of very large platforms and search engines to 28.

“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,” said Henna Virkkunen, the Commission’s executive vice-president for tech sovereignty, security and democracy. “We continue to watch the digital landscape closely and will not hesitate to designate any platform that meets the threshold for enhanced supervision under the Digital Services Act.”

How the companies responded

“ChatGPT search operates as a search service under the DSA, and we are preparing to meet the additional compliance requirements that come with this Very Large Online Search Engine designation,” OpenAI spokesperson Oscar Haines told Politico. Reddit, which reported 57.2 million EU users in July, said through spokesperson Jen Molina: “We’ve been preparing to meet the VLOP requirements and look forward to coordinating with EU regulators while providing transparency for Reddit users.”

Roblox, with 46.6 million EU users, sat just above the line. “We are proud to be the first gaming platform to reach this milestone in the EU,” said Joost Hagesteijn, its general manager for Europe.

ChatGPT was already regulated in Brussels under the AI Act, and the DSA has reached generative AI before: X’s Grok chatbot is under investigation under the law, the Financial Times reported. The Commission says its digital rules apply wherever a company is based; in July it fined Chinese marketplace AliExpress €550 million under the DSA over illegal products.