EU Regulates ChatGPT as a Search Engine Under DSA 2026

The European Union has found a new way to regulate ChatGPT: by treating it as a Very Large Online Search Engine (VLOSE) under the Digital Services Act (DSA). This designation, announced by the European Commission, marks a significant shift in how regulators view generative AI tools that also function as gateways to online information.

ChatGPT was initially seen as a text-based chatbot capable of answering questions, summarizing documents, and generating ideas. But as its capabilities expanded, it began to resemble a search engine—a space Europe has been trying to regulate for years. Now, Brussels has given this hybrid nature a regulatory name.

What Brussels Decided

The European Commission has officially designated ChatGPT as a Very Large Online Search Engine (VLOSE) under the DSA. This decision is part of a broader package that also includes Reddit and Roblox, though those platforms were classified as Very Large Online Platforms (VLOP)—a different category.

For ChatGPT, the key point is that Brussels no longer views it solely as a generative AI chatbot. Instead, it sees a service that can also operate in the realm of online search, triggering a much stricter set of obligations.

Why It's Called a Hybrid

The term “hybrid” is important because it captures how Brussels has chosen to classify a service that doesn't function like a traditional search engine but isn't limited to conversation either. According to the Commission, ChatGPT can interact with user queries in ways that go beyond simple chat—it can provide information, answer questions, and even guide users toward web content.

This hybrid nature means ChatGPT falls under rules designed for search engines, which include transparency requirements, risk assessments, and audits. It's a recognition that AI chatbots are becoming a primary interface for finding information online.

What This Means for ChatGPT and AI Regulation

The VLOSE designation brings ChatGPT under the DSA's most stringent rules. These include obligations to assess and mitigate systemic risks, undergo independent audits, and provide users with more transparency about how the service works.

For OpenAI, the company behind ChatGPT, this means adapting to a regulatory framework that was originally designed for social media platforms and search engines. It also sets a precedent for how other AI-powered services might be regulated in the future. The longer history behind the story is traced in EU Regulates ChatGPT as a Search Engine Under DSA.

• Stricter oversight: ChatGPT must now comply with DSA rules for very large search engines, including risk management and audits.
• Hybrid classification: The EU recognizes that AI chatbots can function as search engines, blurring traditional categories.
• Precedent for AI: This decision could influence how other AI tools are regulated globally.
• Transparency requirements: OpenAI will need to provide more information about how ChatGPT operates and handles user queries.
• Broader package: Reddit and Roblox were also designated as VLOPs, showing the EU's widening regulatory net.

How ChatGPT Compares to Traditional Search Engines

While ChatGPT is now classified as a search engine, it operates quite differently from Google or Bing. The table below highlights key differences. The background to this story is set out in Regulate Social Media for Teens Like Television Now. A related thread runs through OpenAI's Invisible Watermark for ChatGPT Text in Europe. Earlier coverage in German Search Engine Ecosia Ditches Mistral for Chinese Open-Source AI Models shows how the argument developed.

What to Watch Next

The designation is likely to face scrutiny from OpenAI and other AI companies, who may argue that ChatGPT is not a search engine in the traditional sense. However, the EU's move signals a willingness to adapt existing regulations to new technologies. A closer look at the same subject appears in Ultra-Processed Foods: FSA Must Update Guidance and Regulate. Anyone following the wider picture can start with Social Media Regulation Failure Fuels Disinformation Crisis. The same theme surfaces in Technology: latest articles, which takes a different angle.

As AI tools become more integrated into how we access information, the line between chatbot and search engine will continue to blur. The EU's decision could inspire similar actions in other jurisdictions, shaping the global regulatory landscape for AI. Context on how this played out before sits in Denmark's Deepfake Law: Protecting Your Face and Voice from AI. A companion piece, AI Safety Regulation: Why Global Action Can't Wait, approaches the same subject from another angle.

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