The EU executive has designated GPT chat as a Very Large Online Search Engine under the Digital Services Act on Monday. The move brings transparency and risk-mitigation duties to the search parts of ChatGPT, while leaving chat-based uses in a less settled legal zone.
ChatGPT and the DSA
The designation can expose OpenAI to fines of up to 6% of its annual global revenue if it misses the requirements. For users, that means the parts of ChatGPT that function like a search tool now sit under a stricter EU regime similar to Google and Microsoft’s Bing.
The Commission took just under a year to reach the decision. That pace matters because the law was finalized in 2022, before chatbots became central enough to strain the old categories built for search and social platforms.
Christel Schaldemose on risks
Christel Schaldemose, the Danish socialist MEP and key negotiator for the law, said: "ChatGPT is much more than a search engine and there are also risks connected to the chatbot itself which fall outside the (regulation’s) strongest obligations". She added that those risks include "such as emotional dependency and manipulative or addictive design".
João Pedro Quintais, an associate law professor at the University of Amsterdam, described ChatGPT as "a hybrid". That label fits the legal split here. The EU chose the search-engine route, but the chatbot’s own conversations are not clearly swept into the same obligations.
What the designation covers
Asking ChatGPT to name the candidates in a local election should now fall under the DSA. A conversation with the chatbot about who to vote for may not. That difference leaves OpenAI with a narrower compliance target than a full Very Large Online Platform classification would have created.
That narrower scope is the unresolved part for users and regulators. How the Commission will treat ChatGPT’s advice, companionship, and other non-search conversations under the DSA is still the question that will decide how far this ruling reaches.
