EU designates ChatGPT a Very Large Online Search Engine under the DSA

The European Commission has formally designated ChatGPT as a Very Large Online Search Engine (VLOSE) under the Digital Services Act, after the service reported at least 45 million average monthly users in the European Union. The designation puts ChatGPT into the DSA’s highest-supervision tier for search services.\n\nThe immediate effect is regulatory rather than a product feature change. OpenAI now has four months from notification to comply with the additional VLOSE obligations. Those include assessing and mitigating systemic risks connected to illegal content, minors, physical and mental wellbeing, fundamental rights, electoral processes and public security. The Commission becomes the central supervisor for these enhanced obligations.\n\nFor ChatGPT users and enterprise buyers, the designation matters because it creates a new EU accountability layer around a general-purpose AI service that increasingly behaves as an information-discovery interface. It does not mean ChatGPT has been found in breach of the DSA, and it should not be confused with the separate EU AI Act framework for general-purpose AI models. The trigger here is service scale and classification under the DSA.\n\nThe Commission says ChatGPT crossed the threshold through its declared EU user count. The practical changes users eventually see may depend on OpenAI’s compliance implementation, risk assessments and any later supervisory action; the designation itself does not prescribe a specific interface change today. AiToolMap will treat this as a material governance update to ChatGPT rather than evidence about model quality or capability.