What changed
The European Commission designated ChatGPT as a Very Large Online Search Engine under the Digital Services Act after it reported at least 45 million monthly EU users. OpenAI has four months, until January 2027, to meet the additional VLOSE obligations.
Why it matters
ChatGPT now enters the DSA's highest supervision tier for search services, adding formal duties around systemic-risk assessment, mitigation, transparency, minors, wellbeing, fundamental rights, elections, public security, and independent scrutiny.
What to do
EU-facing product, legal, trust, ads, safety, and audit teams should map every DSA obligation to an owner, evidence artifact, deadline, risk assessment, researcher-access process, incident path, and tested mitigation before January.
Caveat
Designation is not a finding that ChatGPT violated the DSA. Exact obligations, interfaces, supervisory requests, audit scope, and implementation choices will develop during the four-month compliance period and need legal interpretation.