Summary
- The European Commission designated ChatGPT a "Very Large Online Search Engine" and Reddit and Roblox "Very Large Online Platforms" under the Digital Services Act.
- The threshold is 45 million average monthly EU users, and all three services must comply with rules on minor protection, ad restrictions, and algorithmic transparency by the end of December 2026.
- OpenAI unveiled a voluntary plan for responsible AI rollout in Europe on July 31 — and within a month, it became subject to legally binding regulation.
EU slaps ChatGPT with a "very large search engine" label
The European Commission announced that it has designated ChatGPT a "Very Large Online Search Engine" (VLOSE) under the Digital Services Act (DSA). OpenAI now carries a legal obligation to manage risks tied to minor protection, user mental health, and the spread of illegal content. The same day, the Commission also designated Reddit and Roblox as "Very Large Online Platforms" (VLOPs).
To put this in context: OpenAI itself rolled out a voluntary plan on July 31 to promote responsible AI use across Europe. This new Commission designation is separate from that self-imposed commitment — it locks ChatGPT into a legally binding regulatory category regardless of what OpenAI pledged on its own.
The DSA classifies any online service with more than 45 million average monthly users in the EU as "very large" and subjects it to stricter rules. ChatGPT, Reddit, and Roblox have all been confirmed to exceed that threshold, and each must comply with the new requirements by the end of December 2026.
What actually changes
Once a service gets the "very large" designation, it can no longer run ads targeted at minors, and it's barred from using sensitive user data — sexual orientation, religion, ethnicity, political views — to target ads. Companies also take on a new obligation to disclose, in more detail, how their recommendation algorithms work.
For ChatGPT specifically, the notable part is being classified as a "search engine." ChatGPT has generally been understood as a conversational AI assistant, but as its web-search and information-lookup capabilities have grown, the EU has effectively placed it in the same regulatory bucket as established search engines like Google.
OpenAI's voluntary plan becomes a legal duty within a month
On July 31, OpenAI rolled out its own plan to advance responsible AI across Europe. At the time, it looked like a voluntary move aimed at both getting ahead of regulators and expanding in the market. A month later, though, the European Commission formally designated ChatGPT as subject to legally binding rules — turning what OpenAI had framed as self-directed commitments into mandatory obligations.
Henna Virkkunen, the EU's Executive Vice-President for Tech Sovereignty, Security and Democracy, said the designation means the company will face "a higher level of scrutiny and accountability."
Same regulatory timeline for all three services
| Service | Designation | Compliance deadline |
|---|---|---|
| ChatGPT | Very Large Online Search Engine (VLOSE) | December 2026 |
| Very Large Online Platform (VLOP) | December 2026 | |
| Roblox | Very Large Online Platform (VLOP) | December 2026 |
These three services are fundamentally different in nature, yet a single yardstick — the size of their EU user base — has put them under the same regulatory umbrella. Roblox skews heavily toward young users, Reddit runs on anonymous communities, and ChatGPT is a conversational AI — each carrying its own distinct risks — but the DSA applies the same standard across all of them.
What this means for Korean companies and users
This decision applies within the EU, but it's not irrelevant to Korean companies and developers who use ChatGPT for business purposes. OpenAI could end up applying the same algorithmic-transparency disclosures and minor-protection policies it adopts for EU compliance to its global service as well. Regulators in other countries also frequently look to how companies respond to the DSA when designing their own rules, so Korean regulatory bodies have reason to pay close attention to this designation.
Editor's take
The most notable part of this designation is that the EU classified ChatGPT as a "search engine" rather than a "chatbot." OpenAI has consistently positioned ChatGPT as a conversational AI assistant, but as more users have started relying on it to actually look things up, regulators made their call based on real-world usage rather than branding. It's a clear illustration of a basic regulatory principle: what matters legally is what a service actually does, not what the company calls it.
Placing OpenAI's July announcement of a voluntary responsible-AI plan for Europe side by side with this new designation makes the gap between voluntary commitments and legal obligations pretty stark. A voluntary plan lets a company set its own pace, but DSA compliance comes with a hard December deadline and penalties for missing it. It's a good reminder that, when dealing with regulators, legal status counts for more than good-faith promises.
For Korean companies, there are two practical things worth watching. First, if you've integrated the ChatGPT API or related services into your own products, keep an eye on how OpenAI adjusts its ad and data policies to meet EU standards — those changes could ripple into your own service. Second, if your service has users under 18, be aware that ad-targeting restrictions and algorithmic-transparency requirements born in the EU have a track record of spreading to other regions' regulations too.
Over the next few months, the thing to watch is whether OpenAI builds a separate EU-only policy track ahead of the December deadline or simply rolls the same standards out globally. It'll also be worth watching how Reddit and Roblox choose to respond.
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