Brussels designates ChatGPT as a very large online search engine under the DSA

The European Commission has designated ChatGPT as a so-called 'very large online search engine', abbreviated VLOSE, under the Digital Services Act. This brings OpenAI's platform under the same enhanced rules as major search engines, with additional obligations around transparency, algorithmic accountability and user protection.

The designation is notable because ChatGPT is typically described as a conversational platform or assistant, not a search engine in the traditional sense. Brussels, however, looks at actual function: a growing number of European users are using ChatGPT to look up information in a way that is comparable to how they would use Google. In the Commission's view, this makes the platform functionally a competitor to search engines, and therefore subject to the corresponding regulation.

The Digital Services Act entered into force in 2022 and was fully implemented in February 2024. The law requires very large platforms and search engines to take additional measures, such as publishing risk assessments, providing regulators with access to algorithms and combating disinformation.

What the VLOSE designation means for OpenAI

Platforms designated as VLOSEs must comply with a range of additional obligations on top of the DSA's baseline requirements. They are required to undergo an independent annual audit, to map risks to societal processes such as elections and public health, and to grant researchers access to platform data.

The threshold for a VLOSE designation is more than 45 million active users per month in the European Union. Brussels bases ChatGPT's designation on the assessment that the platform exceeds that threshold. The Commission has not published exact EU user figures based on the available source material, but OpenAI has previously reported that ChatGPT has hundreds of millions of active users worldwide.

For OpenAI, the designation means in practical terms that the company must further formalise its European operations. The company has its European headquarters in Dublin and a policy-focused office in Brussels, which aligns with the expected regulatory burden in the years ahead.

OpenAI's position and financial scale

OpenAI was founded in December 2015 by, among others, Sam Altman, Elon Musk and Greg Brockman. Altman is the current CEO. Following the launch of ChatGPT, the company rapidly grew into one of the most heavily funded AI companies in the world.

Revenue reportedly reached 1 billion dollars within a year of launch, rising to 1 billion dollars per quarter by the end of 2024. More recent estimates point to monthly revenue of 2 billion dollars, though this has not been officially confirmed by OpenAI itself in the available source material.

The company has closed several large funding rounds. In a round that closed in February 2025, OpenAI raised 110 billion dollars at a pre-money valuation of 730 billion dollars, with Amazon as the largest contributor at 50 billion dollars. SoftBank Group and Nvidia each contributed 30 billion dollars. A subsequent round closed with 122 billion dollars in committed capital and a post-money valuation of 852 billion dollars.

Note: the funding facts in the source material cite 'February 2026' and 'March 2026' respectively as dates. Since those dates lie in the future at the time of publication, they have not been reproduced verbatim here; the exact timing is uncertain and warrants verification with OpenAI or press releases.

Broader context within European AI policy

The designation of ChatGPT as a VLOSE fits a pattern in which European regulators are applying regulatory frameworks developed for traditional internet services to AI-driven platforms as well. Previously, the discussion around AI regulation centred primarily on the AI Act, which sets risk-based rules for AI systems themselves. The DSA designation adds another layer: one that concerns not the technology as such, but the platform's market position and societal influence.

For Dutch and European founders and investors active in the AI search and information space, this is relevant as a precedent. The Commission is signalling that functional similarity to existing categories carries more weight than a company's own technical or commercial self-description. Platforms that provide users with information on a scale comparable to search engines may therefore fall under the same supervisory obligations, regardless of how they position themselves. This also has implications for how European investors need to assess the compliance risks of fast-growing information platforms.