What the designation carries
The Very Large Online Search Engine label is the DSA's top tier. It comes with obligations the company hasn't faced before: regular risk assessments, transparency reports, and a duty to hand regulators detailed information about how the service works. The rules target systemic problems — disinformation, illegal content, manipulation of elections — and require companies to show they're actively hunting for those risks, not just reacting when something goes wrong.
The company also has to make its systems open to outside scrutiny. That includes audits of how its tools rank and present information, and a requirement to explain, in plain terms, how answers are generated. For users, the practical effect is more disclosure: clearer information about what the chatbot does with their data and how it arrives at the answers it gives.
Why ChatGPT fits the category
The Commission's decision rests on how people actually use ChatGPT. It's no longer just a chatbot that chats. Users ask it to summarize news, compare products, answer factual questions, and point them toward sources — functions that overlap heavily with what a search engine does. Under the DSA, the label follows the function, not the name. A service that behaves like a search engine, even if it calls itself something else, can be treated as one.
That functional test is
