What it is
A Very Large Online Search Engine (VLOSE) is a legal category created by the European Union’s Digital Services Act (DSA), the EU’s core law for regulating online platforms. Under Article 33 of the DSA, any online search engine that reaches 45 million or more average monthly active users in the EU — roughly 10% of the bloc’s population — can be formally designated a VLOSE by the European Commission. The same threshold, applied to platforms rather than search engines, creates the parallel category of Very Large Online Platform (VLOP), which already covers services such as Facebook, Instagram, YouTube, and TikTok.
On 31 August 2026, the Commission designated OpenAI’s ChatGPT a VLOSE — the first time a conversational AI chatbot has received this classification. In the same announcement, the Commission designated Reddit and Roblox as VLOPs. The Commission justified treating ChatGPT as a search engine by describing it as a “hybrid service”: because it can engage with and respond to user prompts and queries, including by searching the web for current information, it falls within the DSA’s functional definition of an online search engine even though it does not present users with a conventional list of ranked links. OpenAI had reported that ChatGPT’s search functionality reached approximately 159.1 million average monthly active recipients in the EU over the six months ending 31 March 2026 — more than three times the designation threshold.
Why it matters for AI governance and narratives
The VLOSE designation is significant less for what it changes technically than for what it signals about how regulators are choosing to fit generative AI into pre-existing legal frameworks rather than waiting for AI-specific rules (such as the EU AI Act) to fully apply. By classifying ChatGPT as a search engine, Brussels is asserting that a law written with Google in mind can be stretched to cover a fundamentally different kind of interface — one that synthesizes and converses rather than ranks and links. This is a live contest in EU digital policy: commentary from legal scholars (see Verfassungsblog, below) has argued that treating chatbots as search engines is a reasonable and even necessary reading of the DSA’s functional, technology-neutral definitions, given that conversational AI increasingly performs the same discovery function search engines once monopolized.
For the observatory’s purposes, the designation is a useful marker of how regulatory institutions frame AI systems in relation to older technologies, and of the leverage that framing creates. Once a service is designated a VLOSE, it inherits a specific accountability regime — systemic risk assessment, independent audits, and vetted-researcher data access — that was designed for search and social platforms, not for generative dialogue systems. Whether that regime meaningfully governs an AI chatbot’s actual risks (hallucination, manipulation, dependency effects) or merely repurposes an ill-fitting toolkit is an open question the DSA’s implementation will test over the coming compliance cycle.
Key facts and dates
- Legal basis: Article 33 of Regulation (EU) 2022/2065 (the Digital Services Act), which sets the 45-million-average-monthly-EU-user threshold for VLOP/VLOSE designation.
- Designation date: 31 August 2026. The Commission designated ChatGPT as a VLOSE and Reddit and Roblox as VLOPs in the same announcement.
- Compliance deadline: Designated services have four months from notification to comply with the DSA’s heightened obligations (Articles 34–43) — for this cohort, a deadline around the end of January 2027.
- Obligations triggered: annual systemic-risk assessments covering illegal content, harm to minors, effects on users’ physical and mental well-being, fundamental rights, electoral processes and public security; independent external audits; data-access mechanisms for vetted researchers; and additional transparency requirements around advertising and recommender systems.
- Prior designations: The Commission first designated a group of VLOPs and VLOSEs (including Google Search, Bing, Facebook, and others) in April 2023, when the DSA’s largest-platform provisions first took effect. The August 2026 round is a subsequent expansion of that list and the first to include a generative AI chatbot.
Where to learn more
- European Commission: “Commission designates ChatGPT, Reddit, Roblox under Digital Services Act” — the Commission’s own announcement, the primary source for the designation.
- Digital Services Act, Article 33 (via DSA Library) — the statutory text defining VLOPs and VLOSEs and the 45-million-user threshold.
- Verfassungsblog: “Searching for Answers: Why the EU Commission Should Designate Chatbots as Search Engines under the DSA” — an academic legal analysis of the reasoning behind classifying chatbots as search engines.
- Euronews: “EU places ChatGPT, Reddit and Roblox under strictest digital safety rules” — independent news coverage confirming the designation and its practical effects.