The hybrid that searches: ChatGPT joins Europe's very large search engines

The European Commission has placed ChatGPT in the category of very large online search engines (VLOSE) under the Digital Services Act (DSA), alongside Google Search and Bing. In the same decision of 31 August 2026, Reddit and Roblox were designated very large online platforms (VLOP). It is the first time a conversational assistant built on generative artificial intelligence has been brought under the European Union's strictest regulatory regime. Executive Vice-President for Technological Sovereignty Henna Virkkunen said the designations will bring ChatGPT, Reddit and Roblox “greater scrutiny and accountability in the EU, in line with their large societal impact”.

According to the Commission's official list, ChatGPT (legal entity OpenAI Ireland Limited) has 159.1 million average monthly active recipients in the European Union, comfortably above the 45 million threshold set by the regulation. The figure should be read for what it is: it comes from the declaration OpenAI Ireland Limited publishes under Article 24(2) of the DSA, and it refers to ChatGPT's search functionality over the six months ending 31 March 2026. Next to it, the official list reports 364 million for Google Search and 119 million for Bing, without saying how those numbers were counted: a direct comparison between the three does not hold up. The Commission's documentation does not clarify whether the designation covers the whole service or only that functionality.

Treating ChatGPT as a search engine rests on its nature as a “hybrid service”, a description carried by press sources, under which the system answers user queries partly by searching the web. The classification moves the focus away from the commercial label of chatbot and onto the functional one of search tool. As a result, OpenAI will have to meet the DSA's additional obligations, which include assessing systemic risks tied to illegal content, the protection of minors and electoral processes. On timing, the Commission's statement says designated services have four months, that is until January 2027, to comply with those additional obligations. Euronews also speaks of four months but points to the end of November 2026: the Commission's own text prevails, though the notification date from which the clock runs is not public. No public statement from OpenAI on the designation has emerged so far, and the statement mentions no formal investigations opened into the three services.

Framing a generative artificial intelligence as a search engine because of its browsing functions shows a European regulator that trusts how a service is actually used over how it is marketed. But the most telling technical omission is still the missing distinction, in the official documents, between the conversational interface and the search engine underneath it. The obligations of the next four months will run along exactly that line, and for now neither the statement nor the list draws it. — Olya