The European Commission has officially designated ChatGPT as a Very Large Online Search Engine (VLOSE) under the Digital Services Act. This designation requires OpenAI to implement systemic risk management and mitigation measures, creating a dual-regulatory framework alongside the EU AI Act.
This designation ends the legal ambiguity for standalone generative AI services, moving them from a regulatory grey zone into the same high-scrutiny tier as Google and Bing. For the streaming and digital media ecosystem, it establishes a precedent where conversational AI interfaces are treated as search intermediaries, requiring transparency in how they synthesize and rank information sources. The move forces a complex coordination between the EU AI Office and DSA enforcement teams to prevent overlapping compliance burdens. Industry observers should watch for the January 2027 compliance deadline to see how OpenAI adjusts its text watermarking debuts and source attribution to satisfy Article 34 risk assessments.
The European Commission approves new framework for AI transparency, which will work in tandem with these new DSA obligations to ensure that generative models remain accountable to both users and regulators. The commission is also expanding its platform risk oversight to ensure that large-scale services provide the necessary data for independent audits, while broader EU AI Act compliance efforts continue to shape the operational landscape for developers.
The European Commission has officially designated ChatGPT as a Very Large Online Search Engine (VLOSE) under the Digital Services Act. This move forces OpenAI to implement systemic risk management and independent audits by January 2027, as the service now faces the same high-scrutiny regulatory standards as major search engines like Google.
ChatGPT was designated as a VLOSE because it surpassed the 45 million-user threshold, reaching 120.4 million monthly EU users as of October 2025.
OpenAI is required to implement systemic risk mitigation and meet VLOSE standards by January 2027.
Regulators will focus on monitoring risks related to electoral processes, the protection of minors, and the dissemination of illegal synthetic content.
The designation moves ChatGPT out of a regulatory grey zone, subjecting it to the Digital Services Act's high-scrutiny tier alongside platforms like Google and Bing.
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