The European Commission has officially designated ChatGPT as a Very Large Online Search Engine under the European Union’s Digital Services Act, placing the AI service under a stricter level of regulatory supervision.
The decision was announced on August 31, 2026. According to the Commission, ChatGPT reported at least 45 million average monthly users in the European Union—the threshold required for this designation.
OpenAI now has four months, or until January 2027, to comply with the additional requirements that apply to the European Union’s largest online platforms and search engines.
The decision does not mean that ChatGPT has been banned or found guilty of breaking European law. Instead, it means OpenAI must follow additional rules covering safety, transparency, accountability and systemic risks.
Key points
- ChatGPT has been classified as a Very Large Online Search Engine, or VLOSE.
- The service reported at least 45 million monthly users in the European Union.
- OpenAI has until January 2027 to meet the additional requirements.
- The rules cover illegal content, minors’ safety, fundamental rights, elections, public security and user wellbeing.
- ChatGPT will face more direct supervision from European regulators.
- The designation does not immediately change ChatGPT access for ordinary users.
- Reddit and Roblox were also designated under the Digital Services Act.
Why did the EU classify ChatGPT as a search engine?
ChatGPT began primarily as a conversational artificial-intelligence assistant. Its capabilities have since expanded to include live web search, source discovery and responses based on current online information.
The European Commission described ChatGPT as a hybrid service because it can respond to user prompts while also searching the web. This search capability allowed the Commission to classify it as an online search engine under the Digital Services Act.
The designation is based on both the nature of the service and its reach within the European Union.
Services with more than 45 million average monthly EU users may be classified as Very Large Online Platforms or Very Large Online Search Engines. These services face stricter obligations because their algorithms and decisions can affect a significant portion of the European population.
What must OpenAI do next?
OpenAI will have to assess the systemic risks connected to ChatGPT and introduce appropriate measures to reduce those risks.
The European Commission says large platforms and search engines must examine risks involving:
- Illegal or harmful content
- Freedom of expression and other fundamental rights
- Protection of children and teenagers
- Physical and mental wellbeing
- Discrimination and consumer protection
- Public security
- Elections and democratic processes
- Gender-based violence and public health
OpenAI may need to show regulators how ChatGPT detects, reduces or responds to these risks.
The exact changes made to ChatGPT will depend on OpenAI’s compliance plan and discussions with European regulators.
Greater transparency and independent audits
Very large online services must provide more information about how their systems operate.
This may include increased transparency around content moderation, advertising and recommendation systems. Users should receive clearer explanations when content is limited or removed, where those DSA provisions apply.
Designated services are also subject to independent audits. These audits examine whether the company is properly identifying risks and following the required mitigation measures.
OpenAI may additionally need to share certain information with the European Commission and national authorities for regulatory assessment.
Qualified researchers can also receive access to relevant platform data when their research helps identify or understand systemic risks in the European Union. Such access remains subject to legal, privacy and security safeguards.
Will ChatGPT change for ordinary users?
The designation does not automatically introduce an immediate visible change for every ChatGPT user.
However, European users may eventually notice:
- Clearer safety and content-moderation information
- Improved methods for reporting potentially illegal content
- More explanations about important platform decisions
- Additional protections for children and teenagers
- Greater transparency regarding algorithmic systems
- New privacy, safety or account controls
- More information about advertising if advertisements are introduced or displayed
OpenAI has not yet published a complete list of product changes specifically resulting from this designation.
Users should therefore be cautious about claims that a particular ChatGPT feature has already been removed or restricted because of the announcement.
Does this mean ChatGPT violated the law?
No violation was established by the designation itself.
The European Commission designated ChatGPT because the service met the user threshold and qualified as an online search engine—not because the Commission had concluded that OpenAI committed an offence.
The decision creates additional responsibilities and gives regulators stronger authority to examine the service’s features and risk-management practices.
Any future finding of non-compliance would require a separate investigation and enforcement process.
Difference between the DSA and the EU AI Act
The Digital Services Act and the EU AI Act are separate regulatory frameworks.
The EU AI Act focuses specifically on the development and use of artificial-intelligence systems. It contains rules for prohibited AI practices, high-risk systems, general-purpose AI models and transparency.
The Digital Services Act covers online intermediaries, platforms and search engines. Its focus includes illegal content, user rights, platform transparency, advertising, recommendation systems and broader societal risks.
ChatGPT may therefore have obligations under both frameworks, but the latest designation was made under the Digital Services Act.
What this means for developers and businesses
Developers using the OpenAI API are not automatically classified as Very Large Online Search Engines merely because their products use OpenAI models.
However, businesses serving European customers should monitor future changes to OpenAI’s documentation, product controls and contractual terms.
Development teams should maintain clear records showing:
- Which AI models and APIs their applications use
- What user data is transmitted to AI providers
- How long submitted data is stored
- Whether human review is available
- How users can report harmful or incorrect output
- How AI-generated content is labelled
- Which safeguards are used for minors
- How the application handles copyrighted or illegal material
Using a third-party AI API does not remove a developer’s responsibility to follow the laws and contractual requirements that apply to the final product.
Companies operating in regulated industries may need additional legal, privacy and security reviews before deploying generative AI.
Relevance for Bangladeshi freelancers
The European Union’s decision does not directly impose the same platform-level obligations on an ordinary Bangladeshi ChatGPT user.
However, it can still affect Bangladeshi freelancers, agencies and software companies that provide services to European clients.
A European client may require a freelancer to explain:
- How ChatGPT is used within a project
- Whether personal or confidential data is submitted
- How AI-generated work is reviewed
- Whether users know when they are interacting with AI
- What happens when the AI produces harmful or inaccurate content
- Whether the application has reporting and appeal procedures
Bangladeshi developers should avoid entering client secrets, personal information or protected business data into an AI service without permission.
Freelancers should also review client contracts before using AI to write content, analyse documents, create software or process customer information.
What happens next?
OpenAI has until January 2027 to comply with the additional Digital Services Act obligations created by the designation.
The European Commission will supervise ChatGPT’s compliance in cooperation with Ireland’s Digital Services Coordinator, as OpenAI’s relevant European operations are established in Ireland.
Possible next steps include risk assessments, independent audits, transparency reports and new safety or reporting mechanisms.
The full effect on ChatGPT will become clearer when OpenAI announces its compliance measures or European regulators publish further information.
For now, ChatGPT remains available, and the designation should be understood as an expansion of regulatory oversight rather than a ban.
Sources and transparency
This report was independently prepared by BlogerHub using information published by the European Commission. It does not reproduce the wording of the original announcement.
Sources:
- European Commission announcement on ChatGPT’s DSA designation
- EU rules for very large online platforms and search engines
- OpenAI guidance concerning European AI regulation
This article provides general information and should not be treated as legal advice.
