What it is
“Very large online search engine” (VLOSE) is a legal category created by the European Union’s Digital Services Act (DSA), the bloc’s main platform-accountability law. It is not a marketing term or a technical description — it is a regulatory tier. Under the DSA, any search engine that reaches at least 45 million average monthly active users in the EU can be formally “designated” by the European Commission as a VLOSE, which triggers a distinct and more demanding set of legal obligations than apply to smaller services.
The Commission made its first VLOSE designations in April 2023, naming Google Search and Bing alongside 17 “Very Large Online Platforms” (VLOPs) such as Facebook and TikTok. In August 2026, the Commission added a third VLOSE: OpenAI’s ChatGPT. The Commission’s reasoning was that OpenAI had turned ChatGPT into what it called a “hybrid service” — a conversational assistant that can also autonomously fetch and cite live web results, rather than requiring a user to manually invoke a separate search mode. On that basis, the Commission classified ChatGPT as a search engine for regulatory purposes, and found its EU user base — reported at roughly 159 million average monthly users — far exceeded the 45-million threshold. Roblox and Reddit were designated as VLOPs in the same round.
The VLOSE/VLOP designation is deliberately about scale and reach, not about a service’s underlying technology. A search engine or platform does not choose this status; the Commission assigns it based on user numbers the company itself must report, and the designated service then has a fixed compliance window — typically four months — to meet the additional requirements.
Why it matters for AI governance and narratives
The ChatGPT designation is one of the first concrete instances of an EU digital-regulation regime originally built for social media and web search being extended to a general-purpose AI system. That extension is itself a contested framing question: is a conversational AI assistant that can browse the web meaningfully the same kind of thing as Google Search, subject to the same disclosure, audit, and researcher-access rules? The Commission’s answer — yes, on the facts of how ChatGPT now operates — sets a precedent that could pull other AI assistants with web-retrieval features into the same regulatory category as they cross the user threshold.
For the observatory’s purposes, the designation is also a useful test of a recurring narrative dynamic: which actors treat implementation of systemic-risk obligations as the substantive story, versus which treat the designation itself as the story. Coverage from specialist outlets has emphasized that the designation is easy to announce and hard to operationalize — for instance, how a DSA requirement for non-profiling recommendation options (Article 38) applies to a system that synthesizes conversational answers rather than ranking a list of links, or how the DSA’s ad-transparency rules interact with OpenAI’s newly introduced advertising in ChatGPT. Notably, OpenAI did not contest the search-engine characterization, which is itself an editorially relevant data point: it suggests the company chose not to fight the label, at least publicly, rather than that the classification is uncontroversial on the merits.
Key facts and dates
- April 25, 2023: The European Commission issued its first VLOP/VLOSE designation decisions under the DSA, naming 17 Very Large Online Platforms and 2 Very Large Online Search Engines (Google Search and Bing).
- 45 million users: The DSA’s designation threshold — average monthly active users in the EU — for both VLOPs and VLOSEs.
- August 2026: The Commission designated ChatGPT (operated by OpenAI Ireland Limited) as a VLOSE, and named Roblox and Reddit as VLOPs, based on ChatGPT’s reported ~159.1 million average monthly EU users.
- Four months: The standard compliance window designated services are given to meet DSA obligations after notification.
- Core VLOSE/VLOP obligations: systemic-risk assessment and mitigation, independent audits, provision of data access to vetted researchers, and periodic content-moderation/transparency reporting.
As of this writing, reporting indicates the systemic-risk obligations applicable to ChatGPT’s designation have not yet been tested in practice, and no public account has surfaced of OpenAI or the wider AI industry contesting the classification itself — a silence that specialist coverage treats as notable given the stakes of the precedent.
Where to learn more
- European Commission — List of designated VLOPs and VLOSEs — the Commission’s official, maintained registry of designated services and user-count figures
- European Commission — “Digital Services Act: Commission designates first set of Very Large Online Platforms and Search Engines” (April 2023) — the original designation announcement and criteria
- TechPolicy.Press — “ChatGPT, Roblox Face Tough EU Rules. Implementation Is the Hard Part” — the specialist analysis referenced in the editorial passage, detailing the practical compliance challenges
- heise online — “DSA: EU Commission classifies ChatGPT as ‘very large search engine’“ — independent news confirmation of the designation and its basis