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Digital Services Act

ChatGPT nears EU regulatory heavyweight status

Bloomberg reported on July 29 that the European Commission is preparing to designate ChatGPT's search function as a "Very Large Online Search Engine" (VLOSE) under the EU's Digital Services Act (DSA) — the bloc's strictest platform-oversight tier — with confirmation possible as soon as August. Roblox is separately expected to be designated a "Very Large Online Platform" (VLOP) in the same announcement.

AI Navigate Editorial2026.07.317 min read

2026.1.15 Meta blocks rival AI on WhatsApp 2026.6.9 EU interim order forces reopening 2026.7.13 ChatGPT returns to WhatsApp 2026.8 (expected) VLOSE designation (not yet final)
01
Why Now

The end of "special treatment"

The EU is starting to oversee AI assistants on the same footing as search and social giants

Bloomberg reported on July 29, 2026, and updated the story on July 30, that the European Commission is in the final stages of deciding to designate ChatGPT's search function as a "Very Large Online Search Engine" (VLOSE) under the DSA. Per Bloomberg's report, an official decision could come as soon as August — but as of July 31, 2026, the European Commission has not yet made a formal announcement, so this remains an anticipated outcome, not a done deal.

This is not an isolated move. After Meta blocked rival AI assistants — ChatGPT, Copilot, Perplexity — from WhatsApp starting January 15, 2026, the EU issued an interim order on June 9 forcing Meta to reopen the door. The Decoder reported that ChatGPT subsequently returned to WhatsApp in the EU on July 13. Barely six weeks later, a designation under the DSA's strictest tier is now being reported — a pattern that shows the EU folding AI assistants into its existing Big Tech oversight framework rather than treating them as a new, separate category.

02
The Numbers

"45M" is not ChatGPT's user count

Conflating the legal threshold with the actual figure badly understates the scale

45M threshold 45M DSA designation legal threshold 120M+ ChatGPT overall EU monthly users 159M Search function EU monthly users
FIG. 45M is the legal threshold; 120M+ and 159M are the reported actual EU monthly user figures for ChatGPT
45M
DSA designation legal threshold (average monthly EU users)
120M+
ChatGPT's overall EU monthly users (OpenAI disclosure, six-month average through Sept. 2025)
159M
Search function's EU monthly users (most recently reported figure)
6%
Maximum fine for violations (share of global annual turnover)

It's an easy mix-up: "45M" is not ChatGPT's user count — it's the legal threshold (45 million average monthly EU users) that triggers VLOP/VLOSE designation under the DSA. ChatGPT's actual EU user base is far higher: OpenAI's own disclosure (a six-month average through September 2025) put it at over 120 million, and heise online's reporting of Bloomberg's more recent figures puts the search function alone at roughly 159 million — more than 3x the designation threshold.

03
Two Tiers, Same Rigor

ChatGPT gets VLOSE, Roblox gets VLOP

Same "strictest tier" — but the formal designation names differ

Another detail often missed in this story is the distinction between categories. Per Bloomberg's reporting, ChatGPT's search function is expected to be designated a "Very Large Online Search Engine" (VLOSE), while Roblox — reported to have roughly 48 million monthly EU users, much closer to the 45M line — is expected to be designated a "Very Large Online Platform" (VLOP). The two are formally distinct DSA categories, but the obligations they trigger are roughly equivalent — it's most accurate to describe them together as the DSA's strictest oversight tiers (VLOP/VLOSE), rather than simply calling ChatGPT a "VLOP."

ChatGPT (search function)Roblox
Expected category: VLOSE (Very Large Online Search Engine)Expected category: VLOP (Very Large Online Platform)
Reported EU monthly users: ~159 millionReported EU monthly users: ~48 million
Relative to 45M threshold: far above itRelative to 45M threshold: close to the line
Expected timing: as soon as August 2026Expected timing: as soon as August 2026 (likely same announcement)
04
Who's Affected

Who this hits, and how

Everyday users will barely notice. The impact lands on operators

Teams running EU operations

Once formally designated, a 4-month compliance clock starts for systemic risk assessments, independent audits, and transparency reporting. Budgeting for the compliance overhead is worth starting now.

General users

This is primarily a backend supervisory obligation, so day-to-day ChatGPT usage shouldn't change much in the near term. Think of it as more accountability and auditing for the operator, not a feature change.

Regulatory watchers

The sequence from the WhatsApp interoperability order in June to this designation expected in August is worth tracking as a signal the EU is folding AI assistants into ongoing systemic oversight.


05
What's Next

What happens next

01

Watch for the official August designation

The Commission's formal announcement is reported as possible "as soon as August," but neither the timing nor the exact scope is confirmed yet. Until an official release lands, this remains anticipated.

02

Track the 4-month compliance clock once it lands

Once formally designated, a 4-month window opens for systemic risk assessments, independent audits, and transparency reporting. Plan a schedule anchored to the designation date.

03

EU businesses relying on ChatGPT should start preparing now

Naming a regulatory point of contact, reviewing terms and conditions, and budgeting for the annual supervisory fee are items best started before the designation is confirmed, not after.

Not yet a decision.
Just a step toward a planned future.


06
Caveats

This is not "official" yet

As of now, this is investigative reporting by Bloomberg, not an announcement from the European Commission. The timing could slip, or the scope could change from what's currently reported. There's also a less-discussed tradeoff: the compliance costs that come with VLOP/VLOSE status could indirectly slow the pace of feature rollouts and product priorities specifically within the EU. Resources spent on audits and transparency reporting are resources not spent elsewhere — the balance between regulatory effectiveness and the pace of AI assistant development is worth watching going forward.