A New Legal Category, Not Just a New Rule
On August 31, 2026, the European Commission designated ChatGPT as a Very Large Online Search Engine (VLOSE), and Reddit and Roblox as Very Large Online Platforms (VLOPs), under the EU's Digital Services Act. All three services had declared at least 45 million average monthly users in the bloc, the threshold the DSA sets for its strictest oversight tier.
| Service | DSA Category | Established In | Supervising Regulator |
|---|---|---|---|
| ChatGPT (OpenAI) | Very Large Online Search Engine | Ireland | Coimisiún na Meán, with the European Commission |
| Very Large Online Platform | Ireland | Coimisiún na Meán, with the European Commission | |
| Roblox | Very Large Online Platform | Netherlands | Authority for Consumers and Markets, with the European Commission |
The designation puts all three in a group of 28 platforms and search engines the Commission has now placed under this strictest DSA tier, where oversight runs through Brussels directly rather than through national regulators alone.
Why The Search-Engine Label Is The Real Story
The designation itself was not a surprise. The classification underneath it is: this is the first time the Commission has slotted an AI chatbot into the search-engine track rather than the platform track, and the reasoning it gave is what makes the precedent travel beyond ChatGPT.
The Commission's own explanation is that ChatGPT 'is an Artificial Intelligence (AI) system that can engage with and respond to users' prompts and queries, including by searching the web,' which makes it 'a hybrid service that qualifies as an online search engine under the DSA.' Any assistant that can browse the live web on a user's behalf, not just a product built around a search box, now has a documented path into the same compliance track as Google or Bing.
What Changes By January 2027
The three services have four months from notification, until the end of January 2027, to comply with the extra obligations that come with VLOP and VLOSE status: assessing and mitigating systemic risks tied to illegal content, harm to minors, users' physical and mental wellbeing, fundamental rights, electoral processes and public security, submitting to independent audits, and opening data access to regulators and vetted researchers.
ChatGPT, Reddit and Roblox were already covered by the DSA's general obligations for platforms and search engines. The VLOP and VLOSE tier sits on top of that baseline, and it does not arrive gradually: for any digital product approaching 45 million EU users, the compliance workload jumps at that line rather than climbing with it.
The Same Two Regulators, Again
The Commission gains direct investigative powers over all three services, but it exercises them 'in cooperation with' the national Digital Services Coordinator where each company is legally established: Coimisiún na Meán in Ireland for ChatGPT and Reddit, and the Authority for Consumers and Markets (ACM) in the Netherlands for Roblox. Those are the same two jurisdictions that already host the EU legal entities of most large US platforms.
The stakes for missing the deadline are not abstract. Penalties for non-compliance with DSA VLOP and VLOSE obligations can reach 6 percent of a company's global annual turnover, on top of the reputational cost of being one of 28 named services under the bloc's strictest tier.
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