EU Names ChatGPT a 'Very Large' Search Engine; Reddit and Roblox Also Designated Under DSA

The European Commission said Monday it has designated ChatGPT as a Very Large Online Search Engine, or VLOSE, and Reddit and Roblox as Very Large Online Platforms, or VLOPs, under the European Union’s Digital Services Act, placing all three services under the law’s toughest level of oversight.

The move is significant not only because it adds three widely used services to the DSA’s highest-supervision tier, but because it treats ChatGPT as a search engine for the law’s purposes. Until now, the Commission’s public list of designated VLOSEs included traditional search products such as Google Search and Bing. By adding ChatGPT, the EU is extending that category to an AI-based search product.

Under the DSA, newly designated VLOPs and VLOSEs have four months to comply with the extra obligations tied to that status. For Monday’s decision, that means ChatGPT, Reddit and Roblox must meet those requirements by Dec. 31, 2026. Once designated, the services also come under direct European Commission supervision rather than remaining primarily with national regulators.

The DSA reserves the “very large” label for services with at least 45 million average monthly active recipients in the EU, measured over a six-month period — roughly 10% of the bloc’s population.

The Commission’s designations follow the companies’ own DSA user disclosures showing they had crossed that threshold.

OpenAI said ChatGPT Search had about 159.1 million average monthly active recipients in the EU for the six-month period ending March 31, 2026. Reddit said it had no more than 57.2 million monthly active recipients in the EU, averaged over Jan. 1, 2026, to June 30, 2026. Roblox said its estimated EU average was 46.6 million for the six-month period ending Aug. 13, 2026.

The categories matter because they determine which parts of the DSA apply most heavily. A VLOP is a very large online platform, while a VLOSE is a very large online search engine. The Digital Services Act is the EU’s main law for platform accountability and transparency, and the “very large” tier carries the strictest compliance burden.

For ChatGPT, the designation stands out because the Commission is applying the search-engine category to a product built around AI-generated responses and search functions, not only to conventional search engines. That broadens the reach of the DSA framework beyond the established search products already on the Commission’s list.

The additional obligations for designated services include assessing and mitigating systemic risks, undergoing independent audits, meeting stronger transparency requirements and providing certain data access to regulators and vetted researchers. Where applicable, designated services also must maintain advertising repositories.

The designation is not a finding that any of the companies violated the law. But it does trigger the DSA’s most demanding compliance rules and gives the Commission the lead enforcement role. For serious noncompliance, the law allows fines of up to 6% of a company’s global annual turnover.