On 31 August the European Commission designated ChatGPT a very large online search engine under the Digital Services Act. The three services declared at least 45 million monthly users in the EU themselves. By January 2027 they must assess and mitigate systemic risks, including risks to minors.
- ChatGPT is designated a very large online search engine (VLOSE); Reddit and Roblox are very large online platforms (VLOP).
- The deadline for the new obligations is four months from notification, which means January 2027.
- The risks they must assess: illegal content, harm to minors, physical and mental well-being, fundamental rights, elections, public security.
Forty-five million. Above that line the Digital Services Act stops treating you as an ordinary service.
ChatGPT, Reddit and Roblox told the Commission themselves that they are above it. On 31 August it put them in the category with additional obligations. ChatGPT goes in as a search engine, Reddit and Roblox as platforms.
What it means in practice. From January, the risks of what a chatbot tells you must also be assessed and mitigated under the DSA, under the Commission's supervision.
Why the word search engine matters
The choice of category shows how Brussels sees the chatbot: as a place people go to find an answer. Not as a place where they publish.
Roblox is the other story. A platform built around a game now formally has to assess harm to minors. Brussels is pushing on the same point with TikTok, since July.
Four months is short for a document of this scale. The first risk assessments will show who writes them seriously and who writes them out of politeness.