The European Commission has expanded the most stringent supervision regime of the Digital Services Act (DSA) to three new tech giants, fundamentally redefining the legal nature of ChatGPT. For the first time, an AI chatbot has been classified as a Very Large Online Search Engine (VLOSE), while Reddit and Roblox have been designated as Very Large Online Platforms (VLOPs).
ChatGPT: From Chatbot to Search Engine
Brussels' move sets a crucial regulatory precedent. The Commission concluded that because ChatGPT pulls live results from the internet to answer user prompts, it functions as a "hybrid service" that operates as a search engine rather than just an AI platform. This is backed by OpenAI's own data, showing approximately 159 million monthly active users in the EU for its search functionality during the six months ending March 2026.
Compliance Obligations and Systemic Risks
The three services have four months—until the end of November—to comply with a suite of high-level obligations. This includes mandatory annual systemic risk assessments covering illegal content, the protection of minors, mental and physical wellbeing, fundamental rights, and electoral integrity. Furthermore, they must submit to independent audits and grant vetted researchers access to their internal data.
Financial Penalties and Geopolitical Friction
The stakes are high, as the DSA has already resulted in roughly €870 million in fines against platforms like AliExpress and Temu. Non-compliance could lead to penalties of up to 6% of a company's global annual turnover, a potentially massive sum for the rapidly growing OpenAI.
This enforcement drive is sharpening tensions with Washington. The Trump administration has previously characterized EU digital fines as a "novel form of economic extortion," threatening retaliation against countries targeting US tech firms. This friction coincides with the EU's broader concerns regarding AI safety and the potential loss of human control over autonomous systems.
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