<!-- mobian-agent-page publisher="dailydev" canonical="https://daily.dev/posts/chatgpt-designated-as-very-large-online-search-engine-under-the-eu-s-digital-services-act-pzdofgnvl" -->

---
title: ChatGPT designated as Very Large Online Search Engine...
description: The European Commission has designated ChatGPT as a Very Large Online Search Engine under the Digital Services Act, the first AI chatbot to fall under this...
canonical: https://daily.dev/posts/chatgpt-designated-as-very-large-online-search-engine-under-the-eu-s-digital-services-act-pzdofgnvl
twitter:card: summary_large_image
twitter:site: @dailydotdev
og:type: website
og:site_name: daily.dev
og:title: ChatGPT designated as Very Large Online Search Engine under the EU&#x27;s Digital Services Act | daily.dev
og:description: The European Commission has designated ChatGPT as a Very Large Online Search Engine under the Digital Services Act, the first AI chatbot to fall under this...
og:url: https://daily.dev/posts/chatgpt-designated-as-very-large-online-search-engine-under-the-eu-s-digital-services-act-pzdofgnvl
og:image: https://api.daily.dev/og/posts/pZDofGNvL.png
og:image:alt: ChatGPT designated as Very Large Online Search Engine under the EU&#x27;s Digital Services Act
og:image:width: 1200
og:image:height: 630
og:locale: en
---

> ## Documentation Index
> Fetch the complete documentation index at: https://daily.dev/llms.txt
> Use this file to discover all available pages before exploring further.

# ChatGPT designated as Very Large Online Search Engine under the EU's Digital Services Act

**[Collections](https://daily.dev/sources/collections)** · 2 min read · 7 upvotes · 8 comments

## Summary

The European Commission has designated ChatGPT as a Very Large Online Search Engine under the Digital Services Act, the first AI chatbot to fall under this regime. Reddit and Roblox were simultaneously designated as Very Large Online Platforms, each having crossed the DSA's 45-million monthly EU user threshold (ChatGPT 159M, Reddit 57.2M, Roblox ~48M). The designation requires annual systemic risk assessments, independent audits, and regulator/researcher data access, with a compliance deadline at the end of November and fines up to 6% of global annual turnover for serious violations. OpenAI's risk assessment will focus on electoral processes and public security, Roblox on child safety, and Reddit on its role as an AI training data source. EU users may see slower feature rollouts as a result.

## Content

The European Commission has designated ChatGPT as a Very Large Online Search Engine (VLOSE) under the Digital Services Act, making it the first AI chatbot to fall under this regulatory regime. Reddit and Roblox were simultaneously designated as Very Large Online Platforms (VLOPs).

All three crossed the DSA's 45-million monthly EU user threshold. ChatGPT reported 159.1 million monthly EU users, Reddit 57.2 million, and Roblox roughly 48 million.

## What the designation requires

Under the DSA, ChatGPT now faces:

- Annual systemic risk assessments covering illegal content, child safety, mental wellbeing, fundamental rights, electoral processes, and public security
- Independent annual audits
- A public, year-long ad repository
- Data-sharing obligations with regulators and vetted researchers studying systemic risks

OpenAI has four months to comply. Ireland's digital services coordinator will supervise. Fines for serious violations can reach 6% of global annual turnover.

One notable carve-out: a stricter DSA rule banning ads profiled on sensitive data applies to platforms, not search engines, so it may not apply to ChatGPT under this designation.

## Why "search engine" and not "platform"

The choice of label matters more than it might seem. Designating ChatGPT as a platform (VLOP) would have triggered safe harbour protections that implicitly treat a model's outputs as third-party content - effectively giving OpenAI a liability shield. The Commission avoided that by going with the search engine classification, which covers the retrieval-like parts of the tool.

The catch is that the designation doesn't cover open-ended conversation, companionship use, or emotionally manipulative design patterns. Critics including MEP Christel Schaldemose and AccessNow's Daniel Leufer argue this leaves a real gap: the AI Act's systemic-risk framework focuses on existential-scale risks rather than fundamental-rights harms, and the DSA's VLOSE designation doesn't fill that space either. The full designation text hasn't been published yet, so the exact scope of OpenAI's obligations is still unclear.

## The ads angle

Separately, OpenAI's advertising business hit $1 billion in annualised revenue in under 200 days and expanded self-service ad buying to Europe, India, the Middle East, and North Africa. Businesses can now purchase ads directly through Ads Manager rather than going through agencies.

The timing is notable: the ad expansion and the DSA designation landed on the same day. Stricter compliance requirements under the DSA could slow future feature rollouts in the EU, even as OpenAI is actively building out its commercial ad infrastructure there.

## Questions this post answers

### Why was ChatGPT designated a Very Large Online Search Engine under the EU Digital Services Act?

ChatGPT was designated because it reported 159 million monthly EU users, well above the DSA's 45-million user threshold that triggers stricter obligations. It is the first AI chatbot to receive this designation, alongside Reddit (57.2 million EU users) and Roblox (roughly 48 million), which were designated Very Large Online Platforms at the same time.

_Track how EU regulation reshapes AI product rollouts and feature availability by following DSA coverage on daily.dev._

### What compliance obligations does the EU Digital Services Act impose on companies designated as Very Large Online Platforms or Search Engines?

Designated companies must conduct annual systemic risk assessments, submit to independent audits, and give regulators and vetted researchers access to platform data. The compliance deadline is the end of November, and fines for serious violations can reach 6% of global annual turnover. OpenAI's assessment will specifically address electoral process and public security risks.

_Developers building EU-facing AI products can follow DSA compliance developments on daily.dev to plan ahead._

## Community take

How the wider developer community reacted, aggregated from 2 discussions and 20 comments across x (as of 2026-09-04).

**TL;DR:** Reaction is largely skeptical, with people framing the designation as regulatory overreach that will slow EU feature rollouts, alongside confusion over why other AI tools aren't similarly classified as search engines.

**Sentiment:** 5% positive · 25% mixed · 70% skeptical

**The case for**

- A few see the compliance requirements as pushing toward more transparent, less biased AI products.

**The pushback**

- Many expect EU users to face delayed feature rollouts and slower updates as a result of compliance obligations.
- Some argue the threshold creates an accidental competitive advantage for non-EU labs like Chinese AI companies that don't trigger the same rules.
- Several question the logic of calling ChatGPT a 'search engine' while other chatbots and local-model harnesses aren't classified the same way.
- Some dismiss the whole move as unnecessary regulatory overreach or 'nanny state' behavior.

**By community**

- x (skeptical): Replies mostly frame the designation as bureaucratic overreach that will slow EU rollouts, with pointed jokes about fines and surveillance rather than support for the regulation.

**Hottest debate:** Whether classifying ChatGPT as a search engine (while other chatbots aren't) makes sense, versus it just being an arbitrary trigger from crossing a user threshold.

**Open questions**

- Why does ChatGPT count as a search engine when comparable tools like Claude or local-model harnesses reportedly don't?
- Will this designation meaningfully slow feature rollouts for EU users going forward?

**Highlights**

> @Hesamation chinese labs dont hit these thresholds in the eu the same way, feels like an accidental moat for them
> — [Greg\_GL\_87 on x · 2 points, 1 comments](https://x.com/Greg_GL_87/status/2094398527690449324)

> @Hesamation Claude is not a search engine then? What about OpenClaw? What about harnesses running local models? Either I am not getting something, or this is extremely dumb.
> — [theaitemp on x](https://x.com/theaitemp/status/2094415768486035634)

> @Hesamation The 45M threshold is the key trigger here Once a platform crosses it, the compliance clock starts and feature rollouts get deprioritized for EU users
> — [hakimieiqbal on x · 1 comments](https://x.com/hakimieiqbal/status/2094394325052342691)

> @Hesamation Search engine designation pulls risk assessments on minors and mental well-being into the same four month clock as content moderation. Slower EU rollouts sounds about right.
> — [DoDataThings on x](https://x.com/DoDataThings/status/2094412733395726634)

> @Hesamation chatgpt, reddit & roblox and every ai company that gets regulated should just stop offering their service in the eu. the eu need their products
> — [wendiliah8 on x](https://x.com/wendiliah8/status/2094465320677212406)

**Source threads**

- [x](https://x.com/Hesamation/status/2094386190157799822) · 0 points · 18 comments
- [x](https://x.com/rohanpaul_ai/status/2094466028235583739) · 0 points · 2 comments

## Community discussion

Top comments from developers on daily.dev.

**@petecapecod** · 3 upvotes

> And there's Europe telling everyone else what to do with their things. Some oversight is good, but this feels heavy

**@daviddennison** · 1 upvotes

> Do the people in the EU ever stop being idiots? I am tired of these countries continuously telling American companies what they can and can't do. Take ChatGPT out of Europe and watch them fall into the stone age. Who cares

**@hardik15** · 1 upvotes

> This is very small use-case, if they only call it search-engine.
>
> EU is already lacking in AI and the latest tech, this makes it more delayed. Along with that Anthropic and some may even more restrict their latest models due this decisions.

**@dacianoua** · 0 upvotes

> The people saying this is bad are all shareholders

---

Tags: [#openai](https://daily.dev/tags/openai), [#chatgpt](https://daily.dev/tags/chatgpt)

[View this post on daily.dev](https://daily.dev/posts/chatgpt-designated-as-very-large-online-search-engine-under-the-eu-s-digital-services-act-pzdofgnvl)

```json
{"@context":"https://schema.org","@graph":[{"@type":"Organization","@id":"https://daily.dev/#organization","name":"daily.dev","url":"https://daily.dev","logo":{"@type":"ImageObject","url":"https://daily.dev/apple-touch-icon.png","width":180,"height":180},"sameAs":["https://twitter.com/dailydotdev","https://github.com/dailydotdev","https://www.linkedin.com/company/daily-dev-ltd"]},{"@type":"WebSite","@id":"https://daily.dev/#website","url":"https://daily.dev","name":"daily.dev","publisher":{"@id":"https://daily.dev/#organization"},"potentialAction":{"@type":"SearchAction","target":{"@type":"EntryPoint","urlTemplate":"https://daily.dev/search?q={search_term_string}"},"query-input":"required name=search_term_string"}}]}
{"@context":"https://schema.org","@type":"TechArticle","headline":"ChatGPT designated as Very Large Online Search Engine under the EU's Digital Services Act","url":"https://daily.dev/posts/chatgpt-designated-as-very-large-online-search-engine-under-the-eu-s-digital-services-act-pzdofgnvl","mainEntityOfPage":{"@type":"WebPage","@id":"https://daily.dev/posts/chatgpt-designated-as-very-large-online-search-engine-under-the-eu-s-digital-services-act-pzdofgnvl"},"datePublished":"2026-08-31T12:05:22.515Z","dateModified":"2026-09-04T18:34:08.426Z","description":"The European Commission has designated ChatGPT as a Very Large Online Search Engine under the Digital Services Act, the first AI chatbot to fall under this...","image":"https://media.daily.dev/image/upload/f_auto,q_auto/v1/posts/ec3a2c3b927ffc747dba3700ba34637e?_a=AQAEuop","thumbnailUrl":"https://media.daily.dev/image/upload/f_auto,q_auto/v1/posts/ec3a2c3b927ffc747dba3700ba34637e?_a=AQAEuop","isAccessibleForFree":true,"articleSection":"Collections","inLanguage":"en","publisher":{"@type":"Organization","name":"daily.dev","url":"https://daily.dev","logo":{"@type":"ImageObject","url":"https://daily.dev/apple-touch-icon.png","width":180,"height":180}},"author":{"@type":"Organization","name":"Collections","logo":"https://media.daily.dev/image/upload/s--fk_6ycEi--/f_auto,q_auto/v1780996001/logos/collections?_a=BAMAMiWQ0","url":"https://daily.dev/sources/collections"},"commentCount":8,"discussionUrl":"https://daily.dev/posts/chatgpt-designated-as-very-large-online-search-engine-under-the-eu-s-digital-services-act-pzdofgnvl","interactionStatistic":[{"@type":"InteractionCounter","interactionType":{"@type":"LikeAction"},"userInteractionCount":7},{"@type":"InteractionCounter","interactionType":{"@type":"CommentAction"},"userInteractionCount":8}],"keywords":"openai,chatgpt","timeRequired":"PT2M"}
{"@context":"https://schema.org","@type":"BreadcrumbList","itemListElement":[{"@type":"ListItem","position":1,"name":"Home","item":"https://daily.dev"},{"@type":"ListItem","position":2,"name":"Collections","item":"https://daily.dev/sources/collections"},{"@type":"ListItem","position":3,"name":"ChatGPT designated as Very Large Online Search Engine under the EU's Digital Services Act"}]}
{"@context":"https://schema.org","@type":"WebPage","@id":"https://daily.dev/posts/chatgpt-designated-as-very-large-online-search-engine-under-the-eu-s-digital-services-act-pzdofgnvl","comment":[{"@type":"Comment","text":"And there’s Europe telling everyone else what to do with their things. Some oversight is good, but this feels heavy","datePublished":"2026-08-31T12:30:42.802Z","url":"https://daily.dev/posts/pZDofGNvL#c-OoSpe4WHc","author":{"@type":"Person","name":"Peter Cruckshank","url":"https://daily.dev/petecapecod","image":"https://media.daily.dev/image/upload/s--ZJhQyKws--/f_auto/v1721235024/avatars/avatar_A9xh33q0QoxtkGoJRCosp"},"interactionStatistic":{"@type":"InteractionCounter","interactionType":{"@type":"LikeAction"},"userInteractionCount":3}},{"@type":"Comment","text":"Do the people in the EU ever stop being idiots? I am tired of these countries continuously telling American companies what they can and can’t do. Take ChatGPT out of Europe and watch them fall into the stone age. Who cares","datePublished":"2026-08-31T14:14:35.638Z","url":"https://daily.dev/posts/pZDofGNvL#c-JEhtI67uM","author":{"@type":"Person","name":"David Dennison","url":"https://daily.dev/daviddennison","image":"https://media.daily.dev/image/upload/s--B3KNHAGa--/f_auto/v1738078799/avatars/avatar_7TJPpokONY1WgTSi3E90W"},"interactionStatistic":{"@type":"InteractionCounter","interactionType":{"@type":"LikeAction"},"userInteractionCount":1}},{"@type":"Comment","text":"This is very small use-case, if they only call it search-engine.\nEU is already lacking in AI and the latest tech, this makes it more delayed. Along with that Anthropic and some may even more restrict their latest models due this decisions.","datePublished":"2026-08-31T13:59:58.267Z","dateModified":"2026-08-31T14:01:15.610Z","url":"https://daily.dev/posts/pZDofGNvL#c-cfNa1p62d","author":{"@type":"Person","name":"Hardik","url":"https://daily.dev/hardik15","image":"https://media.daily.dev/image/upload/s--O0TOmw4y--/f_auto/v1715772965/public/noProfile"},"interactionStatistic":{"@type":"InteractionCounter","interactionType":{"@type":"LikeAction"},"userInteractionCount":1}},{"@type":"Comment","text":"The people saying this is bad are all shareholders","datePublished":"2026-09-01T07:00:55.589Z","url":"https://daily.dev/posts/pZDofGNvL#c-8J590a1YU","author":{"@type":"Person","name":"Dacian Oua","url":"https://daily.dev/dacianoua","image":"https://lh3.googleusercontent.com/a/ACg8ocKWrcprJhNMR5jJrZ3Be4VyWcDTXh-EvcrPo2Mzeg1FbxFYtw=s96-c"}}]}
{"@context":"https://schema.org","@type":"FAQPage","@id":"https://daily.dev/posts/chatgpt-designated-as-very-large-online-search-engine-under-the-eu-s-digital-services-act-pzdofgnvl#faq","mainEntity":[{"@type":"Question","name":"Why was ChatGPT designated a Very Large Online Search Engine under the EU Digital Services Act?","acceptedAnswer":{"@type":"Answer","text":"ChatGPT was designated because it reported 159 million monthly EU users, well above the DSA's 45-million user threshold that triggers stricter obligations. It is the first AI chatbot to receive this designation, alongside Reddit (57.2 million EU users) and Roblox (roughly 48 million), which were designated Very Large Online Platforms at the same time. Track how EU regulation reshapes AI product rollouts and feature availability by following DSA coverage on daily.dev."}},{"@type":"Question","name":"What compliance obligations does the EU Digital Services Act impose on companies designated as Very Large Online Platforms or Search Engines?","acceptedAnswer":{"@type":"Answer","text":"Designated companies must conduct annual systemic risk assessments, submit to independent audits, and give regulators and vetted researchers access to platform data. The compliance deadline is the end of November, and fines for serious violations can reach 6% of global annual turnover. OpenAI's assessment will specifically address electoral process and public security risks. Developers building EU-facing AI products can follow DSA compliance developments on daily.dev to plan ahead."}}]}
```

