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The European Commission has designated ChatGPT a very large online search engine under the Digital Services Act, and two of the three announcements it published that day give different dates for when the obligations bite
The designation itself is straightforward. What is not straightforward is that the Commission published three accounts of it that day, two of them 24 minutes apart state different compliance deadlines, and the underlying decision has not been published, so there is nothing to check any of them against.
Bottom line: On 31 August 2026 the Commission designated ChatGPT a very large online search engine under the Digital Services Act, and Reddit and Roblox very large online platforms. The reasoning treats an AI assistant as a search engine because it answers queries partly by searching the web. The release says the services then have four months to comply with the additional DSA obligations.
Who this affects: Counsel and compliance teams at AI providers with EU users, platform regulatory specialists, and anyone who assumed a conversational AI product sat outside the DSA's platform regime. Also relevant to executives planning systemic-risk assessment capacity.
Issue date: Announced 31 August 2026. The press release carries a note that it was updated at 17:00 the same day.
What changed: ChatGPT becomes the third service ever designated a very large online search engine, after Google Search and Bing. The designation rests on characterising a hybrid AI service as a search engine, which extends the DSA's most stringent tier to a product category that had not previously been in it.
Analysis: Two things about this announcement deserve care rather than speed. The Commission's own texts disagree on the deadline, and the designation decisions have been notified to the providers rather than published, so no primary instrument is available to resolve the disagreement. That means every deadline figure in circulation traces back to one of those three accounts, and they do not all match.
Primary sources: European Commission press release IP/26/1772, 31 August 2026 · IP/26/1772 full text (presscorner API rendition) · Commission news item, Digital Strategy · Commission Daily News MEX/26/1775, 31 August 2026 · Commission list of designated VLOPs and VLOSEs
- Instrument
- Designation decisions under the Digital Services Act, announced by press release IP/26/1772
- Authority
- European Commission
- Parent instrument
- Regulation (EU) 2022/2065, the Digital Services Act
- Jurisdiction
- European Union
- Services designated
- ChatGPT as a very large online search engine; Reddit and Roblox as very large online platforms
- Status
- Announced 31 August 2026. The designation decisions themselves are recorded by the Commission as not yet available.
- Bindingness
- The release states the services have four months from notification to comply with the additional DSA obligations for very large online platforms and search engines. This report is based on the Commission's own announcements, because the decisions have not been published.
- Editorial Note
- Informational analysis for working professionals, not legal advice. Confirm how any rule applies to your situation with qualified counsel.
- Primary source
- https://ec.europa.eu/commission/presscorner/api/documents?reference=IP/26/1772&language=en
What the Commission decided, and the reasoning it gave
The Commission announced on 31 August 2026 that it has designated ChatGPT as a very large online search engine under the Digital Services Act, and Reddit and Roblox as very large online platforms.
The reasoning for the ChatGPT designation is given in a single sentence, and it is the sentence that matters most for anyone building a conversational AI product with European users. The release states that ChatGPT is an Artificial Intelligence system that can engage with and respond to users' prompts and queries, including by searching the web, and that hence ChatGPT is a hybrid service that qualifies as an online search engine under the DSA.
The trigger is scale. The release says these services declared that they reach at least 45 million average monthly users in the EU and thus meet the threshold for designation. The declaration is the providers' own; the release presents the figures as declared rather than as found by the Commission.
Per-service user numbers do not appear in the release at all. They appear on the Commission's list of designated services, which records ChatGPT at 159.1 million, Reddit at 57.2 million and Roblox at 46.6 million average monthly EU users, again on a provider-declared basis. Anyone citing a per-service figure is citing the list, not the announcement.
This makes ChatGPT the third service ever placed in the search-engine tier, after Google Search and Bing. The Commission's list now runs to 25 very large online platforms and 3 very large online search engines.
The deadline the Commission gives twice, differently
Three Commission surfaces carried this designation on 31 August 2026, and they split two ways on the deadline. All three contain the same sentence about it, word for word, except for the deadline itself.
The press release IP/26/1772 states that following the notification of the designations, these services have four months, i.e. by January 2027, to comply with the additional DSA obligations for VLOPs and VLOSEs. The Commission's news item on its Digital Strategy site carries the same wording, also saying January 2027.
The Commission's Daily News summary MEX/26/1775, published 24 minutes later, states that these services have four months, i.e. by the end of December 2026, to comply with the additional DSA obligations.
Four months from 31 August is arithmetically adjacent to both formulations. But a compliance date is not a rounding question, and this desk is not going to pick one for you.
Two further facts belong on the record without a theory attached to them. The press release carries a note that it was updated at 17:00 on 31 August. The Daily News item carries no such marker. No changelog is published, so what the update altered is not on the public record.
Why nobody can settle it from the public record
Normally a disagreement of this kind would be resolved by reading the instrument. Here there is no published instrument to read.
The Commission's own list of designated services records the entry for each of the three services in identical terms: designation, decision not yet available, press release. The same column links the actual decision document for older designations, so the list distinguishes between decisions it has published and decisions it has not. These three sit on the unpublished side.
The release's own language is consistent with that. It refers to the notification of the designations, not to their publication.
The consequence for reporting is precise. The compliance deadline exists in the public record only through the disputed sentence. There is no published decision against which January 2027 and the end of December 2026 can be adjudicated, which is why the conflict is not resolvable from open sources and why we print both.
It also fixes the evidentiary status of everything in this report. The Commission's releases are the institution talking about its own decision. That removes journalistic mediation, which is a real gain, but it is not the operative text, and it cannot be relied on for the decision's exact scope or conditions.
What the release actually says the obligations are, and what it does not say
The release names two things. The services must assess and mitigate the systemic risks stemming from their service and algorithmic systems, related to the dissemination of illegal content, the negative effects on minors, users' physical and mental well-being, fundamental rights, electoral processes and public security. And the Commission gains investigative powers to assess the functionalities behind these services.
That is the whole of it. The release does not mention independent audit, vetted-researcher data access or advertisement repositories.
The Commission's standing policy page on the VLOP regime describes further duties for designated services, including independent audit, vetted-researcher data access and advertisement repositories. That page is dated 19 May 2026 and therefore pre-dates this designation. Attributing those duties to the 31 August announcement would be putting words in the Commission's mouth on a day when its choice of words is already in question.
The practical planning point is unaffected by the deadline dispute. Whether the date is the end of December 2026 or January 2027, a first systemic risk assessment for a conversational AI product is not a four-week exercise, and the difference between the two candidate dates is smaller than the uncertainty in most delivery plans.
A second inconsistency, on who supervises Reddit
The deadline is not the only place where the Commission's surfaces do not line up.
The press release states that the Commission will be competent to supervise compliance with the DSA, in cooperation with Coimisión na Meán for ChatGPT and Reddit, and the Authority for Consumers and Markets for Roblox, and describes these as the Digital Services Coordinators respectively for Ireland and for the Netherlands.
The Commission's list of designated services, however, records Reddit's provider as Reddit Netherlands B.V. and places it under the Netherlands as Digital Services Coordinator.
Both cannot be right about Reddit. We are not resolving it here, and anyone who needs to know which authority to deal with should not take either surface as settled.
One small point of accuracy that cuts the other way. The press release misspells the Irish regulator, which is correctly Coimisiún na Meán. Where this report quotes the release it reproduces the release's spelling, because a quotation that silently corrects its source is no longer a quotation.
What to do about it
If you operate a conversational AI service with European users, the reasoning is the part to read closely rather than the headline. Scale was still a necessary condition: the release says the services declared at least 45 million average monthly EU users and thus met the threshold. What is novel is the second half, the characterisation of a hybrid service that answers queries partly by searching the web as an online search engine. Whether that characterisation reaches other products is not something this designation decides.
For teams already in scope, plan to the earlier of the two dates. That is a risk-management choice rather than a legal conclusion, and it costs little given that the two candidate dates are weeks apart.
Do not build a compliance calendar entry that cites a single deadline as settled. Record both figures and their sources, and note that the decision is unpublished, so that when the position is clarified your own file shows why you held two dates rather than looking as though you got it wrong.
Watch for publication of the decisions. The Commission's list is where that would show, because it already distinguishes published decisions from unavailable ones, and a published decision is the document against which the deadline could finally be checked.
Keep the proportion. On the release's own account this is a designation that starts a compliance clock and gives the Commission investigative powers, not a finding that any of the three services has done anything unlawful. Nothing in the announcement alleges a breach.
The Commission designated ChatGPT a very large online search engine under the Digital Services Act on 31 August 2026, alongside Reddit and Roblox as very large online platforms, on the reasoning that ChatGPT is a hybrid service that qualifies as an online search engine because it answers user queries including by searching the web. The release says designation starts a four-month compliance clock, but the Commission stated that clock two different ways on the same day: IP/26/1772 and its Digital Strategy news item say by January 2027, while Daily News MEX/26/1775 says by the end of December 2026. The designation decisions have been notified to providers and not published, which the Commission's own list confirms by recording decision not yet available, so there is no primary instrument against which either date can be checked. Everything reported here therefore rests on the Commission talking about its own decision. Plan to the earlier date as a risk choice, record both with their sources, and do not treat a single deadline as settled until the decisions are published.
Source File
https://ec.europa.eu/commission/presscorner/api/documents?reference=IP/26/1772&language=en
Open the Commission press release IP/26/1772 through the presscorner API rendition. The HTML page returned 19,123 bytes on retrieval and did not contain the rationale or threshold sentences quoted here; the API rendition did. Confirm four things: the sentence stating that ChatGPT is an Artificial Intelligence system that can engage with and respond to users' prompts and queries, including by searching the web, and that hence ChatGPT is a hybrid service that qualifies as an online search engine under the DSA; the sentence stating that these services declared that they reach at least 45 million average monthly users in the EU; the deadline sentence giving four months, i.e. by January 2027; and then open Daily News MEX/26/1775 and confirm that its otherwise identical sentence gives four months, i.e. by the end of December 2026. Finally, open the Commission's list of designated VLOPs and VLOSEs and confirm that the entries for ChatGPT, Reddit and Roblox each read designation, decision not yet available, press release.
ChatGPT is an Artificial Intelligence (AI) system that can engage with and respond to users' prompts and queries, including by searching the web. Hence, ChatGPT is a hybrid service that qualifies as an online search engine under the DSA. European Commission, IP/26/1772, 31 August 2026
FAQ
Why is ChatGPT being treated as a search engine?
Because of how the Commission characterised it. The release says ChatGPT is an AI system that can engage with and respond to users' prompts and queries, including by searching the web, and that it is therefore a hybrid service qualifying as an online search engine under the DSA.
When do the obligations actually apply?
The Commission has given two answers on the same day. Its press release and news item say four months, that is by January 2027. Its Daily News summary says four months, that is by the end of December 2026. The designation decisions are unpublished, so neither figure can be checked against the instrument.
Can I read the designation decision?
Not at present. The Commission's list of designated services records the decision as not yet available for all three services, and the release refers to notification of the designations rather than publication. The list does link decision documents for some earlier designations.
What obligations does the release itself name?
Two. Assessing and mitigating systemic risks stemming from the service and its algorithmic systems, covering illegal content, effects on minors, users' physical and mental well-being, fundamental rights, electoral processes and public security; and the Commission gaining investigative powers over the functionalities behind the services. Audit, data access and advertisement repository duties come from the Commission's standing policy page, not from this announcement.
Which regulator supervises these services?
The Commission supervises compliance with the additional obligations. On cooperation the Commission's surfaces disagree for Reddit: the press release pairs Ireland's Digital Services Coordinator with both ChatGPT and Reddit, while the list of designated services places Reddit Netherlands B.V. under the Netherlands. Roblox is paired with the Dutch Authority for Consumers and Markets in the release.
Does this mean the Commission has found a breach?
No. On the release's own account the services were designated because they declared at least 45 million average monthly EU users and because of what the services are. Nothing in the announcement alleges that any of the three has broken the DSA.
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