ChatGPT is no longer just an artificial intelligence product in the eyes of European regulators. The Commission has designated it as a Very Large Online Search Engine under the Digital Services Act, after the service declared that it exceeded the threshold of 45 million average monthly users in the Union. In the same decision, Reddit and Roblox were designated as Very Large Online Platforms.
The consequence is not merely a label. Designated services have four months to comply with the additional obligations laid down by the DSA, including the assessment and mitigation of systemic risks linked to algorithmic systems, illegal content, the protection of minors, fundamental rights, electoral processes, and public security.
AI meets a law designed for platforms
The designation is noteworthy because it demonstrates the DSA’s ability to extend to services that do not resemble traditional social networks. An AI assistant can become a gateway to information and influence what millions of people see, understand, and search for. From this perspective, systemic responsibility does not depend on the presence of a feed.
For OpenAI, this also creates regulatory overlap: the company must navigate the specific framework of the AI Act and, for the relevant features, that of the DSA. For Brussels, it is evidence of the European strategy to leverage complementary instruments rather than waiting for a new law for every technology.
