EU classifies ChatGPT as a very large online search engine under the DSA
The European Commission put ChatGPT, Reddit and Roblox in the Digital Services Act's highest scrutiny tier, with compliance due by the end of December 2026. The transparency rules that come with it don't yet say anything about how ChatGPT sources or cites answers.
Guilherme Hortinha · 2 September 2026
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What changed

The European Commission has designated ChatGPT a Very Large Online Search Engine under the EU's Digital Services Act. Reddit and Roblox were designated Very Large Online Platforms in the same announcement. The three services join the DSA's highest-scrutiny tier, reserved for services with at least 45 million average monthly users in the EU. They have until the end of December 2026 to comply.
What the designation actually requires
The Very Large tier comes with specific obligations, not just a label:
No ad targeting at minors
No ad targeting based on a person's sexual orientation, religion, ethnicity or political beliefs
More transparency about how recommendation algorithms work
Active mitigation of risks tied to minors, user mental health and the spread of illegal content
"These new designations mean that ChatGPT, Reddit and Roblox will now be held to a higher standard of scrutiny and accountability in the European Union, in line with their large impact on our citizens and society," said Henna Virkkunen, the EU's executive vice-president for tech sovereignty, security and democracy.
What it does not say
The obvious read for anyone selling AI visibility is that a "search engine" label means new disclosure rules for how ChatGPT sources and ranks the answers it gives. The announcement does not say that. The transparency duty named here covers recommendation algorithms, the mechanism behind feeds and suggested content. The source does not state whether that duty extends to how ChatGPT selects or cites sources inside a chat answer.
Until the Commission or OpenAI says otherwise, treat the two as separate questions. This designation is confirmed to cover ad targeting, minor safety and algorithmic transparency in general. It is not a confirmed new rulebook for citation behaviour, whatever the label suggests.
Frequently asked questions
Does the DSA designation change how ChatGPT cites or ranks sources in its answers?+
The announcement does not say. It requires transparency about recommendation algorithms in general, but does not state whether that extends to how ChatGPT selects or cites sources for chat answers.
What is the usage threshold for Very Large status under the DSA?+
At least 45 million average monthly users in the EU.
When must ChatGPT, Reddit and Roblox comply with the new rules?+
By the end of December 2026.
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Co-founder & Head of AI Innovation, Index Lab
Guilherme co-founded Index Lab, an AEO/GEO agency that makes brands the answer AI gives across ChatGPT, Gemini and Perplexity, taking clients from zero AI visibility to top recommendations.
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