Is ChatGPT Now Legally a Search Engine in the EU?

Yes. On August 31, 2026, the European Commission designated ChatGPT a Very Large Online Search Engine (VLOSE) under the Digital Services Act (DSA). It's the first AI chatbot to get this label. ChatGPT reported 159.1 million average monthly users of its search feature in the EU, well above the 45 million threshold.

What changed?

ChatGPT now falls under the DSA's strictest rules for search engines. OpenAI must assess and reduce the risks linked to its service and algorithms, including risks around illegal content, minors, user wellbeing, fundamental rights, elections and public security. It has until the end of December 2026 to comply, and serious DSA violations can bring fines of up to 6% of global annual turnover. On the same day, the Commission also designated Reddit and Roblox as very large online platforms.

Why should marketers care?

Because more buyers now use AI to find products and vendors. They ask things like "What are the best tools for X?" or "What are the best alternatives to Z?" On Google, that question returns a list of links. In ChatGPT, it returns a short list of brands the model picked. If yours isn't on it, the buyer may never see you.

Traditional search asks, "Where do we rank?" AI search asks, "Are we part of the answer?"

Does this change how ChatGPT works?

Not directly, as far as we know so far. The impact is mainly regulatory: more obligations and more oversight for OpenAI. But it's a clear signal that AI-powered discovery is now part of search, and worth measuring regularly rather than checking once in a while.

What should brands do now?

Ask the questions your customers actually ask, across ChatGPT and other major AI engines:

• "What are the best tools for [use case]?"
• "Which vendors should I consider for [problem]?"
• "What are the best alternatives to [competitor]?"

Then check three things: Are you mentioned? Are you recommended? Which competitors show up instead? Repeat it every month, because AI answers change as models and sources change.

The bigger picture

SEO isn't going away, and Google still matters. But search is no longer just a page of blue links. When your customers ask AI for recommendations, does your brand make the shortlist? That's something you can measure today, and it's what generative engine optimization (GEO) is about.

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Source: European Commission press release IP/26/1772, "Commission designates ChatGPT, Reddit, Roblox under Digital Services Act", August 31, 2026.