The European Commission has officially designated ChatGPT as a Very Large Online Search Engine (VLOSE) under the European Union’s Digital Services Act (DSA).
The decision, announced on 31 August 2026, marks the first time an AI chatbot has received this classification and further reflects how quickly AI is changing the way people search for and discover information online.
WHAT DOES THE DESIGNATION MEAN?
Under the DSA, online search engines and platforms with at least 45 million average monthly users in the EU can be designated as Very Large Online Services, bringing them under a higher level of regulatory scrutiny.
OpenAI reported approximately 159.1 million average monthly active recipients for ChatGPT in the EU, based on the six months ending 31 March 2026. This placed the service well above the threshold required for VLOSE designation.
ChatGPT will now be subject to additional obligations under the DSA, including assessing and mitigating systemic risks associated with its service and algorithmic systems. It will also face requirements around independent audits, data access for regulators and vetted researchers, and greater transparency around recommender systems and advertising where applicable.
The designation does not represent a finding of wrongdoing. Instead, it recognises ChatGPT’s scale and its role in providing a service that can search the web and return information in response to user queries.
WHY IS CHATGPT BEING TREATED AS A SEARCH ENGINE?
The European Commission describes ChatGPT as a hybrid service that can respond to user prompts and queries, including by searching the web.
This is an important distinction. Search is no longer limited to a traditional list of webpages and links. AI search tools can interpret a question, combine information from different sources, and generate a direct response.
The EU’s decision therefore provides another indication of how the definition of “search” is evolving alongside AI.
ChatGPT joins Google Search and Bing among the services currently designated as Very Large Online Search Engines under the DSA.
WHAT DOES THIS MEAN FOR SEARCH AND DIGITAL VISIBILITY?
For businesses, the development is another sign that AI is becoming an increasingly significant part of the digital landscape.
Being visible online is no longer solely about where a website appears in traditional search results. AI platforms can draw on information from across the web when generating answers, meaning brand presence, content, expertise, and third-party visibility can all contribute to how a business is represented.
This does not mean traditional SEO is becoming irrelevant. Instead, it adds another layer to how businesses need to think about search visibility, including the growing role of AI SEO & GEO in helping brands understand and improve how they appear across AI-generated search experiences.
As AI platforms become more established as destinations for information discovery, understanding how brands appear within these experiences will become increasingly important for digital marketing and SEO strategies.
WHAT HAPPENS NEXT?
ChatGPT has four months from notification of the designation to meet the additional VLOSE obligations, putting the compliance deadline around January 2027. The European Commission will then have greater oversight of how the service manages systemic risks and meets its responsibilities under the DSA.
The designation is another significant step in the development of AI search – and a reminder that the search landscape is changing not just through new technology, but through how that technology is being recognised and regulated.
For marketers and SEO teams, the key question is increasingly not just where a brand ranks, but where and how it appears when people ask AI for an answer.