On August 31, the European Commission officially designated ChatGPT as a very large online search engine (VLOSE) under the Digital Services Act (DSA). This decision fundamentally changes the regulatory landscape for OpenAI, which is now required to implement a comprehensive set of measures to assess and mitigate systemic risks by January 2027.
In addition to ChatGPT, the regulator recognized Reddit and Roblox as very large online platforms (VLOP). This status is automatically granted to services whose monthly audience in the EU exceeds 45 million users. However, ChatGPT demonstrates an impressive scale: according to OpenAI data, from October 2025 to March 31, 2026, the service's search features were used by an average of about 159.1 million people per month in the European Union. This is more than three times the established threshold.
Now ChatGPT is subject to the strict DSA requirements applied to the largest platforms. The company is obliged to identify, assess, and mitigate systemic risks, including:
- the spread of illegal content;
- the protection of minors;
- the physical and mental well-being of users;
- compliance with fundamental rights;
- the impact on elections and public safety.
OpenAI will also be required to establish an internal structure for monitoring DSA compliance, undergo an independent audit at least once a year, and provide reporting to the European Commission and national regulators. Vetted researchers will gain the right to request access to data for studying systemic risks, and mitigation measures may affect the service's algorithmic and recommendation systems.
Sanctions for violating the DSA are severe: a fine of up to 6% of the company's global annual turnover, as well as possible requirements to remedy identified violations. Notably, in August, the European Commission already received the authority to impose fines on providers of general-purpose AI models for violations of the Artificial Intelligence Act, creating dual regulatory pressure on OpenAI.
My analysis: This is a landmark precedent—for the first time, a generative AI service falls under such strict oversight on par with traditional platforms. Given that ChatGPT's audience in the EU is three times the threshold, OpenAI will have to radically rethink its approaches to content moderation and algorithm transparency. In the long term, this could slow the pace of introducing new features in Europe, but it will also create a standard of trust that strengthens the company's position in the global market.