ChatGPT Officially Designated a Very Large Online Search Engine in the EU

ChatGPT as a Very Large Online Search Engine is no longer just an informal label. On August 31, 2026, the European Commission officially designated ChatGPT a Very Large Online Search Engine, or VLOSE, under the Digital Services Act (DSA). This designation makes ChatGPT the first AI chatbot to fall into that category.

This change is covered in a Search Engine Journal report on ChatGPT's status as a Very Large Online Search Engine in the European Union. OpenAI itself reports that ChatGPT search had roughly 159.1 million average monthly active recipients in the EU for the six-month period ending March 31, 2026.

That figure sits far above the DSA's 45-million-active-user threshold. As a result, ChatGPT now falls under additional oversight that was previously more associated with major search engines and digital platforms like Google Search, Bing, TikTok, Amazon, and others.

What Does Very Large Online Search Engine Status Mean?

VLOSE status means an online search service is considered to have an extremely large scale of use in the EU, and is therefore required to meet additional obligations under the Digital Services Act.

In the Digital Services Act, the core threshold for the Very Large Online Platform and Very Large Online Search Engine categories is at least 45 million average monthly active recipients in the EU.

Once a service crosses that threshold and is officially designated by the European Commission, it doesn't just follow the DSA's baseline obligations. It also enters an additional oversight regime covering systemic risk, transparency, audits, researcher access, and accountability.

For ChatGPT, this change matters because EU regulation now treats it not just as a chatbot, but also as an online search engine.

Why Is ChatGPT Categorized as a Search Engine?

The European Commission describes ChatGPT as a hybrid service that meets the definition of an online search engine, since it answers user prompts and queries, including by searching the web.

This reflects a major shift in user behavior.

The information-search flow used to look more like:

User
  ↓
Search engine
  ↓
List of links
  ↓
Website
  ↓
Answer

Now the flow can look like:

User
  ↓
ChatGPT
  ↓
Search + synthesis
  ↓
Direct answer
  ↓
Citation / source if needed

Once an AI assistant already combines search, retrieval, synthesis, and recommendation, its role becomes harder and harder to separate from a traditional search engine's function.

How Many ChatGPT Search Users Are There in the EU?

OpenAI reports roughly 159.1 million average monthly active recipients for ChatGPT search in the EU over the six months ending March 31, 2026.

OpenAI explicitly states this figure was calculated specifically to meet DSA obligations and shouldn't be used for any other purpose.

This matters because "monthly active recipients," in the DSA context, isn't automatically the same as the monthly active users figure typically used in business reporting or market-share claims.

Is 159.1 Million the Total Number of ChatGPT Users in Europe?

It's not accurate to read it that way. The figure OpenAI published is the average monthly active recipients for ChatGPT search specifically in the EU, calculated specifically for DSA purposes.

That means the figure shouldn't be used directly to conclude ChatGPT's total user count, its AI assistant market share, or its number of paying subscribers.

OpenAI itself includes a disclaimer that the figure is for compliance reporting only.

How Long Does OpenAI Have to Meet the Additional DSA Obligations?

The European Commission gives four months from the designation notification.

Since ChatGPT was designated on August 31, 2026, the additional obligations need to be met by roughly January 2027.

During this period, OpenAI needs to build out several new compliance layers, including risk assessment, audits, data access, and transparency obligations.

What Are ChatGPT's Additional Obligations as a VLOSE?

The biggest obligation relates to systemic risk.

The European Commission names risk categories that must be assessed and mitigated, including:

• the spread of illegal content;
• negative impact on minors;
• impact on physical and mental wellbeing;
• fundamental rights;
• electoral processes;
• public security.

That means OpenAI has to look not just at whether one answer violates policy, but at whether its design and algorithmic system can create a systemic risk at scale.

What Is a Systemic Risk Assessment?

A systemic risk assessment is an evaluation of large-scale risk arising from how a platform or search engine operates.

It's not just:

"Is one answer wrong?"

but also:

"Can the system as a whole amplify
disinformation, risk to children, or an impact on elections?"

This shifts the focus of compliance from an individual incident to platform-level behavior.

Does ChatGPT Have to Undergo an Independent Audit?

Yes. Under the DSA, a VLOP and VLOSE must undergo an independent audit at least once a year.

That audit assesses compliance with the relevant obligations and produces recommendations the provider must respond to.

For an AI system like ChatGPT, an audit can become an important mechanism, since a lot of user-facing decisions come from complex algorithmic systems.

Can Researchers Get Access to ChatGPT's Data?

The designation opens a stronger legal pathway for vetted researchers to request access to certain data, if that research relates to systemic risk.

This doesn't mean every user conversation becomes open to researchers.

The DSA distinguishes between data that can be given to regulators, national authorities, and vetted researchers, following specific procedures and purposes.

The strategic value is that a researcher is no longer entirely dependent on scraping or public data when trying to study the impact of a large-scale platform.

Why Does Researcher Access Matter for AI Search?

AI search has several behaviors that are hard to study from the outside alone.

For example:

• how a recommendation changes;
• how a systemic risk spreads;
• how an algorithmic system treats a specific category;
• how content moderation works at scale;
• how exposure changes over a given period.

Researcher access can support far stronger studies than just running a handful of prompts manually.

Does OpenAI Have to Open Up ChatGPT's Algorithm?

Not in the sense of publishing source code or full model weights.

The DSA focuses more on accountability, risk assessment, regulator access, and transparency.

The Commission can request data or information it needs for oversight, and vetted researchers can access certain data if the conditions are met.

But the designation doesn't mean OpenAI has to make all of its intellectual property public.

What's the Connection to a Recommender System?

For a service that uses a recommender system, the DSA can require at least one option that isn't based on user profiling.

Whether and how this obligation applies to any specific aspect of ChatGPT will depend on which functions fall within the regulation's scope.

SEJ frames this obligation as "where applicable," so it wouldn't be accurate to assume every ChatGPT response now needs a non-personalized recommendation toggle identical to a social media feed.

Does ChatGPT Have to Maintain a Public Ad Repository?

If a service displays advertising that falls within DSA scope, a VLOP/VLOSE must maintain a public repository for that advertising.

SEJ again frames this as an applicable obligation.

So VLOSE status doesn't automatically mean ChatGPT currently has a specific practical obligation if the feature that would trigger it isn't being used in a relevant way.

Does This Designation Mean ChatGPT Broke the Law?

No. This is a very important distinction.

A designation isn't a finding of wrongdoing.

The European Commission designates a service as VLOSE based on its scale and character, not because the service has been found to have committed a violation.

The enforcement process is a separate matter entirely.

What's the Potential Fine for Violating the DSA?

Search Engine Journal notes a DSA violation can produce a fine of up to 6% of a company's global annual revenue, depending on the type and severity of the violation.

That figure shows a designation isn't just an administrative label.

Once a platform enters the VLOSE category, compliance risk becomes financially material.

Why Is ChatGPT the First AI Chatbot to Receive This Designation?

Because the scale of its search feature's use has already surpassed the 45-million-monthly-active-user threshold in the EU.

OpenAI reports roughly 159.1 million recipients — more than three times the threshold.

Beyond that, ChatGPT already has a fairly clear function as a search service: a user can enter a query, and the system can search the web to answer it.

What's the Difference Between ChatGPT and Google Search Under the DSA?

Both can now fall into the VLOSE category, but their user experience and system architecture differ.

Precisely because the difference is so large, DSA enforcement against a chatbot search will be an interesting area to watch.

What's the Impact on AI Search Transparency?

The designation could increase demand for transparency around how a large service assesses and mitigates risk.

But marketers shouldn't expect the DSA to automatically make ChatGPT's ranking factors public.

Transparency under the DSA relates far more to:

• systemic risk;
• audits;
• content moderation;
• researcher access;
• regulatory oversight;
• advertising transparency, where relevant.

That's different from disclosing a ranking formula.

Will VLOSE Status Change How Brands Optimize AI Visibility?

Not directly.

This designation is a regulatory change, not a ranking-algorithm change announced by OpenAI.

So there's no basis for saying:

"Because ChatGPT is now VLOSE,
brands need to change structured data X
to show up more often."

What's more relevant for a brand is the broader increase in accountability and transparency across the AI search ecosystem as a whole.

If your team has previously covered AI visibility, citation, or brand recommendation, the internal article Schema for AI Citations: How to Make Your Brand Easier for Machines to Trust can serve as an internal link once the previous article's URL is verified.

What's the Impact on Publishers and SEO Teams?

In the short term, no direct technical SEO change has been announced.

But ChatGPT's official status as a search engine reinforces a structural shift that was already visible before: an AI assistant is now increasingly treated as part of the search ecosystem, not as a chat product standing outside of search.

For an SEO team, this reinforces the need to measure:

• brand mentions;
• citations;
• AI referrals;
• source visibility;
• misrepresentation;
• platform-level differences.

Traditional search and AI search are getting harder and harder to treat as two genuinely separate worlds.

What's the Connection to the DMA and Access to Google Search Data?

SEJ connects this designation to a separate development under the Digital Markets Act.

The DMA and DSA are different regulations.

Under a DMA decision SEJ previously covered, a chatbot with search functionality can meet the definition of an online search engine and, under certain conditions, could potentially gain access to certain search data Google is required to share with rivals.

This latest designation is different, since it places ChatGPT itself as a VLOSE under the DSA.

So:

DMA:
competition and gatekeeper obligations

DSA:
platform/search safety, transparency,
systemic risk, accountability

Can the Designation Be Revoked?

Yes. The European Commission has the authority to revoke a designation if a service stays below 45 million monthly active recipients in the EU for a full year.

That means VLOSE status depends on the service's actual scale and isn't necessarily permanent.

How Has OpenAI Already Been Meeting DSA Obligations?

OpenAI already had several DSA compliance mechanisms in place before this VLOSE designation, including:

• a designated point of contact for authorities;
• a point of contact for EU users;
• illegal content reporting;
• a moderation and appeal process;
• transparency reporting;
• publishing the monthly active recipients figure for ChatGPT search.

VLOSE status adds a much heavier layer of obligation on top of that baseline.

What Should Be Watched Through January 2027?

There are several developments worth watching after this designation.

1. Systemic risk reporting.
2. Independent audit implementation.
3. Researcher data access mechanisms.
4. Additional transparency disclosures.
5. How the Commission applies VLOSE rules to conversational AI.
6. Whether enforcement interpretation differs from classic search engines.

Since ChatGPT is the first AI chatbot to receive this designation, much of the DSA's practical interpretation will develop through subsequent implementation and enforcement.

Why Does This Matter for Generative AI More Broadly?

ChatGPT's designation shows that regulators are starting to treat generative AI as not entirely separate from platforms and search engines.

If an AI product:

• has an extremely large audience;
• answers search queries;
• accesses the web;
• uses algorithmic systems to present information;

then obligations previously applied to major search platforms can start to become relevant.

This has the potential to influence how an AI company designs governance, logging, risk assessment, transparency, and data-access infrastructure.

Does This Mean AI Search Has Already Replaced Google?

No. Regulatory status isn't the same as market leadership.

ChatGPT crossed a fairly high user threshold to be categorized as VLOSE, but the designation doesn't compare market share, total query volume, advertising revenue, or search traffic against Google.

There's only one safe conclusion: ChatGPT search is already large enough in the EU that regulators treat it as a very large search service.

FAQ About ChatGPT as a Very Large Online Search Engine

When did ChatGPT officially become a VLOSE in the EU?

The European Commission designated ChatGPT a Very Large Online Search Engine on August 31, 2026.

How many ChatGPT search users are there in the EU?

OpenAI reports roughly 159.1 million average monthly active recipients for the six-month period ending March 31, 2026.

What's the threshold to become a VLOSE?

The threshold is at least 45 million average monthly active recipients in the EU.

Does the designation mean OpenAI committed a violation?

No. A designation only reflects the service's scale and category. A finding of wrongdoing requires a separate enforcement process.

What are ChatGPT's additional obligations?

They include systemic risk assessment, risk mitigation, an annual independent audit, regulator data access, researcher access, and additional obligations around recommenders and advertising, where relevant.

When must the additional obligations be met?

Four months after the designation notification, or roughly January 2027.

Does this status affect ChatGPT's ranking?

There's no information that the designation changes any ranking or citation system. This is a regulatory change, not an algorithm announcement.

Conclusion

ChatGPT as a Very Large Online Search Engine is now an official status in the European Union. The European Commission designated ChatGPT a VLOSE on August 31, 2026, after OpenAI reported roughly 159.1 million average monthly active recipients for ChatGPT search — far above the 45-million threshold.

That status brings additional obligations under the Digital Services Act, including systemic risk assessment, mitigation, an independent audit, data access for regulators, and access for vetted researchers.

A designation isn't a finding of wrongdoing and doesn't mean OpenAI has directly violated the DSA. It shows that ChatGPT's scale and search function are now large enough to fall under the same oversight regime as Europe's biggest search engines and platforms.

For generative AI, SEO, and digital strategy teams, the most important implication isn't a new "ranking factor." What's changed is AI search's institutional status: ChatGPT is now officially treated by regulators as part of a very large-scale search infrastructure.

If your business wants to build AI visibility monitoring, search intelligence, generative AI governance, or a digital system that needs to adapt to changes in the AI search ecosystem, you can discuss your business's technology needs with our technical team.