EU Tightens the Leash on ChatGPT – or Does It?

ChatGPT’s rise to prominence is nothing short of incredible. When it launched, it caught the world by storm. Some adored it; others abhorred it;

Everybody was using it.

As time progressed and the model evolved, ChatGPT became the most popular AI platform among professional and casual users, whose numbers today count in the billions.

In the EU alone, ChatGPT has nearly 160 million monthly users, meaning it can influence roughly 35%-40% of the total population, whether through AI ads or generated responses.

And the risks scale with influence.

Recognizing the model’s potential to shape opinions and decisions of EU citizens, and the dangers that come with it, the EU Commission made a decision:

ChatGPT requires the most rigorous oversight.

How did the EU Commission label ChatGPT under the DSA?

On August 31, 2026, the European Commission designated ChatGPT as a VLOSE (Very Large Online Search Engine), folding it under the Digital Services Act (DSA) and subjecting it to the EU’s strictest legal requirements. 

This is the first time in history that an LLM (Large Language Model) earned VLOSE status, making it a landmark regulatory move by the EU. As such, it’s not unreasonable to assume other models will get the same treatment as soon as they clear the 45M+ EU users threshold.

Why is ChatGPT labeled a VLOSE and not a VLOP?

Per the EU Commission’s argument, ChatGPT acts as a hybrid service since it can search the live web in response to user queries and redirect users to external sites, which folds it under the VLOSE definition.

To trigger the VLOP (Very Large Online Platform) definition like Reddit and Roblox did, a digital service must have the capacity to disseminate third-party or user-generated content (UGC) to the public at a large regional scale, at the request of a recipient of the service.

ChatGPT does retrieve third-party and UGC sources like Reddit heavily, relying on their info to synthesize the answer, even if it no longer cites them so frequently in visible answers. So, technically, ChatGPT meets the VLOP definition – it only fits VLOSE criteria better.

How will OpenAI change ChatGPT search to comply with the EU DSA VLOSE requirements?

From the technical/functional standpoint, compliance with the EU DSA effectively requires OpenAI to overhaul the crawl, index, and live web retrieval parts of ChatGPT to ensure transparency and enhance users’ safety. This entails addressing five major areas:

• Source transparency:
  • Explaining exactly how ChatGPT decides which websites to trust, crawl, and cite when answering a user query.
  • Offering search options that generate answers without profiling the user’s personal history, location, and behavioral data.
• Mitigation of misinformation risks:
  • Implementing rigorous guardrails so ChatGPT’s web search does not point users toward illegal or dangerous websites and content.
  • Preventing the retrieval and synthesis of coordinated disinformation campaigns or inaccurate polling data during European elections.
• Advertising transparency:
  • Building a publicly searchable ad archive (repository) that must explicitly state who paid for the sponsored placement in a ChatGPT response, as well as what parameters were used to target the user and the total reach of the ad.
• Strict child safety controls:
  • Mandatory inclusion of high privacy, safety, and security settings for minors by defaul.
  • ZERO profiling for minors, including using their search history or data for targeted behavioral advertising.
• (Forced) Data sharing with researchers:
  • Granting secure API access to ChatGPT data to vetted academic and independent EU researchers, for the purpose of studying how its outputs impact public discourse, societal polarization, and mental health in the EU.

OpenAI has until the end of December 2026 to fully comply with enhanced obligations, or risk fines of up to 6% of the company’s global annual revenue.

How will ChatGPT search change following VLOSE designation? 

Although it’s too early to tell, adherence to new rules may lead to an “EU version” of ChatGPT that cites sources more restrictively than its US counterpart or behaves differently when redirecting users to external websites. 

What’s much more interesting is the marketing implications. First, by labeling ChatGPT as VLOSE, the EU Commission effectively elevated its status from “chatbot” to a full-fledged search engine. Now, it’s on par with the only two platforms that ever held that rank: Google Search and Bing.

Second, the designation came less than two weeks after OpenAI rolled out ChatGPT ads to 31 European countries. The timing, paired with the imposed non-profiling and minors-related restrictions, not only highlighted – but actually amplified the platform’s position as a prime advertising channel.

Although the connections are likely coincidental rather than causal, the conclusion is the same: Officially, ChatGPT became subject to the most rigorous legal scrutiny. Unofficially, ChatGPT got acknowledged as one of the prime visibility channels in all of the EU – however indirectly.

Seth Matthews, an AI SEO content writer within ZeroClick Labs, began his career in civil engineering, but his passion for writing drove his deliberate transition into professional content strategy and SEO. The clash of two worlds produced a writer who can effortlessly combine technical precision and narrative clarity with the emotional and psychological impact of creative storytelling.