ChatGPT is no longer being treated merely as a chatbot. On 31 August, the European Commission designated it as a Very Large Online Search Engine, VLOSE, under the Digital Services Act. In the same decision, Reddit and Roblox were designated as Very Large Online Platforms, VLOP.
The formal reason is reaching the threshold set by the DSA: at least 45 million average monthly users in the European Union. But the decision regarding ChatGPT carries broader significance, acknowledging something users had already started doing for some time: using artificial intelligence not only to generate text, but to search for information, navigate sources, and partially replace the traditional search engine.
What the designation entails
ChatGPT, Reddit, and Roblox will have four months from notification to comply with the additional obligations set out by the DSA for very large services. The Commission highlights, among the primary responsibilities, the assessment and mitigation of systemic risks associated with services and algorithmic systems.
These risks include the dissemination of illegal content, negative effects on minors, the physical and mental well-being of users, fundamental rights, electoral processes, and public security.
In other words, moderating individual content is no longer enough. Services must analyze how the overall architecture of the platform—recommendations, ranking, interfaces, and incentives—can produce systemic effects.
Why ChatGPT is a new case
A traditional search engine ranks links. A generative system, on the other hand, can synthesize sources, rewrite them, and present a single answer, reducing the need to visit the original websites. This is a massive difference from an information standpoint.
When a user asks an AI assistant “what happened today” or “what is the best product for me”, the platform is not simply showing a list. It is deciding what information to incorporate, what to omit, how to present it, and with what degree of certainty.
The European designation makes it clear that these choices have effects comparable to those of the ranking systems of major platforms.
The DSA enters the era of assistants
The DSA was designed in an era when digital power was primarily associated with social networks, marketplaces, and search engines. The explosion of generative assistants has rapidly altered the way people access information.
The Commission is therefore applying an existing framework to a product with novel characteristics. It is a major regulatory experiment: understanding how concepts such as systemic risk, algorithmic transparency, and data access can be translated into the context of generative models.
Reddit and Roblox demonstrate how broad the scope of the DSA is
The same decision involves two very different services. Reddit is a platform based on communities, discussions, and participatory ranking; Roblox is an ecosystem of digital experiences with a massive presence of young users.
Their designation demonstrates that the VLOP category does not describe a single business model. Rather, it describes a scale of influence: once a service exceeds a certain size, the Union considers that the risks generated by its operation cannot be managed merely as a private relationship between company and user.
The issue of minors will be central
In 2026, the Commission intensified its focus on the safety of minors online, specifically regarding recommendation systems and privacy settings. In the case of TikTok, Bruxelles also challenged aspects related to platforms' ability to effectively protect minors' accounts and prevent the indiscriminate recommendation of their content.
For Roblox, this front is immediately relevant. For ChatGPT, it becomes relevant in a different way: assistants are increasingly used by teenagers for studying, personal advice, and emotional support. The risk assessment will therefore need to examine not only the content produced, but also the type of relationship that the conversational interface creates with the user.
The big question: who decides what we see?
The Commission's decision comes as the boundary between search, social media, and AI is blurring. Google is incorporating generative answers into results, ChatGPT browses the web, Reddit is becoming a prime source for models, and social platforms are deploying increasingly sophisticated AI to rank feeds.
The common thread is that a handful of algorithmic systems decide an increasing share of the information we are exposed to. The DSA attempts to introduce responsibilities proportionate to this power.
ChatGPT's designation as a VLOSE is therefore much more than a bureaucratic label. It is the institutional recognition that web search is changing form. And when the way people search for information changes, the rules needed to monitor those who select that information change as well.
