ChatGPT just got a new label in Brussels, and it comes with a compliance deadline. The European Commission has designated OpenAI’s chatbot as a Very Large Online Search Engine under the Digital Services Act, grouping it with Reddit and Roblox — both now classified as Very Large Online Platforms. The threshold for that designation sits at 45 million average monthly users in the EU, and all three services have until the end of December 2026 to fall in line.
The DSA’s requirements are not cosmetic. Platforms must stop targeting ads at minors and can no longer use a person’s sexual orientation, religion, ethnicity, or political beliefs for ad targeting. Recommendation algorithms get pulled into the sunlight too, with transparency obligations that force companies to explain how content actually reaches users. For ChatGPT specifically, the Commission framed the designation around mitigating risks to minors, user mental health, and the spread of illegal content.
Henna Virkkunen, the EU’s executive vice-president for tech sovereignty, security and democracy, put it bluntly: “These new designations mean that ChatGPT, Reddit and Roblox will now be held to a higher standard of scrutiny and accountability.” That’s the EU’s playbook — regulate by designation, then let the compliance clock run.
This move echoes what the EU did with TikTok, X, and Meta’s platforms years ago, but applying the Very Large Search Engine category to a generative AI chatbot is new territory. The Commission seems to be signaling that conversational AI is no longer a novelty — it’s infrastructure, and infrastructure gets regulated. OpenAI now faces a two-and-a-half-year runway to prove it can operate transparently in a market that has never hesitated to fine American tech companies. Whether the company treats this as a compliance exercise or an existential negotiation with Brussels remains to be seen.
