On 31 August 2026, the European Commission designated ChatGPT as a VLOSE – a Very Large Online Search Engine – under the Digital Services Act (DSA).
This is an important development, not only from the perspective of digital platform regulation, but also for how we understand Search in 2026.
ChatGPT is no longer just an AI chatbot that generates answers. When it uses web search, it can discover information, identify online sources and build responses based on information found across the web.
And this changes the questions brands should be asking about their online visibility.
What Does VLOSE Mean?
VLOSE stands for Very Large Online Search Engine.
Under the Digital Services Act, online search engines that reach at least 10% of the EU population can be designated as very large services. The threshold currently corresponds to approximately 45 million average monthly active recipients in the European Union.
In ChatGPT’s case, the figure published by the European Commission is 159.1 million average monthly active users in the EU.
On 31 August 2026, the European Commission designated ChatGPT as a VLOSE. On the same day, Reddit and Roblox were designated as VLOPs – Very Large Online Platforms.
The distinction matters: ChatGPT was designated as a search engine, while Reddit and Roblox were designated as online platforms.
Why Is ChatGPT Classified as a Search Engine?
This is one of the most interesting aspects of the designation.
ChatGPT can operate in different ways. It can generate an answer based on information already available to its AI models, or it can use web search to retrieve more recent information from online sources.
From the DSA perspective, its search functionality is central to its classification as a VLOSE.
The European Commission’s designation concerns ChatGPT as a very large online search engine.
This distinction is also relevant to the future of Search.
The difference between an AI conversation and AI-powered search combined with conversation is becoming increasingly important.
What Changes for ChatGPT?
The VLOSE designation brings additional obligations under the Digital Services Act.
These include assessing and mitigating systemic risks associated with the service and its algorithmic systems.
The European Commission identifies risks related to, among other things:
- The dissemination of illegal content;
- Potential negative effects on minors;
- Users’ physical and mental well-being;
- Fundamental rights;
- Electoral processes;
- Public security.
Following notification of the designation, ChatGPT has four months to comply with the additional DSA obligations applicable to VLOPs and VLOSEs. According to the Commission’s announcement, the deadline is in January 2027.
Some of these changes may eventually become visible to users.
For the digital industry, however, the implications go beyond regulatory compliance.
What Does This Mean for Search?
Until recently, when we talked about Search, one of the most important questions was:
Where does my brand rank on Google?
Today, the question is becoming more complex:
What does AI find about my brand?
- Which sources does it identify?
- What information does it use?
- Which entities does it mention?
- Which brands does it recommend?
And perhaps most importantly:
Is my brand relevant and well represented across the sources that AI systems use to retrieve and evaluate information?
This is where AEO – Answer Engine Optimization – and GEO – Generative Engine Optimization – come into the picture.
SEO Is Not Disappearing. Search Is Expanding.
AI Search does not mean that SEO is becoming irrelevant.
Quite the opposite.
Your website, content, topical authority, information structure, relevance and online reputation remain important.
But the Search ecosystem is expanding.
Google continues to evolve with AI Overviews and Google AI Mode, while platforms such as ChatGPT are introducing a different way to discover, retrieve and evaluate information.
In this context, optimization is no longer just about achieving a good position on a search results page.
It is also about building relevant signals of authority and trust so that information about your brand can be discovered, understood and used by AI systems.
Why Do Sources Matter?
When an AI system uses web search, information available online can contribute to the answer presented to the user.
This makes external sources increasingly important.
Some examples include:
- Your official website;
- LinkedIn profiles and content;
- Industry publications;
- Relevant platforms in your sector;
- Reviews;
- Professional profiles;
- Editorial content;
- Other sources that confirm who you are, what you do and which topics you are relevant to.
This is why AI Visibility should not be viewed solely as a content issue on your own website.
It is also a matter of your digital ecosystem.
What Is AI Visibility?
AI Visibility refers to the ability of a brand, professional or organization to be:
- Discovered by AI systems;
- Mentioned in AI-generated answers;
- Associated with topics relevant to its area of expertise;
- Supported by credible sources;
- Recommended when users ask for options, products or service providers.
It represents a different perspective on online visibility.
In traditional Search, the focus is often on rankings and traffic.
In AI Search, other signals also become relevant: brand mentions, citations, the sources used, the context in which a brand appears and how frequently it is recommended.
What Does the VLOSE Designation Mean for SEO, AEO and GEO?
ChatGPT’s designation as a VLOSE is another indication of how the Search landscape is evolving.
Search engines and conversational AI systems are becoming part of how people discover and evaluate information.
For brands, this creates a new need:
To be visible not only in search results, but also in AI-generated answers.
AEO and GEO do not replace SEO.
They build on its foundations.
What Should Brands Monitor?
In this evolving Search ecosystem, brands should consider a number of important questions:
- How does my brand appear in Google Search?
- How does it appear in Google AI Overviews and AI Mode?
- Is it mentioned by ChatGPT, Gemini, Copilot, Claude or Perplexity?
- Which sources do these systems use when providing information about my brand?
- Is my brand recommended when users search for products or services in my category?
- What information can AI systems find about my brand, and is it accurate?
- Are there enough independent sources confirming my authority on relevant topics?
These are questions about AI Search Visibility, not just traditional SEO.
A New Chapter for Search
For me, ChatGPT’s designation as a VLOSE represents more than a regulatory classification change under the DSA.
It is another indication that AI is becoming an essential part of the Search ecosystem.
For SEO and marketing professionals, this means looking at online visibility from a broader perspective.
Not just:
„Where does my brand appear?”
But also:
„What does AI say about my brand?”
As more people use AI to discover, compare and evaluate information, this question will become just as important as a brand’s position in traditional search results.
Sources
- European Commission – Digital Services Act: Very Large Online Platforms and Search Engines (VLOPs and VLOSEs)
- European Commission – Commission designates ChatGPT, Reddit and Roblox under the Digital Services Act
- European Commission – List of designated VLOPs and VLOSEs
Nicoleta Ion
AI Visibility, AEO & GEO Consultant · Digital Marketing Specialist
Nicoleta Ion – AI Visibility, AEO & GEO Consultant with 10+ years of experience in Communication, Digital Marketing and SEO. I work with professionals and brands that want to be easier to discover, understand and recommend in AI Search, from ChatGPT and Gemini to Perplexity and Google AI Overviews. I continuously research how search is evolving and test what influences visibility in AI-generated results.
My latest study – Professional AI Visibility Index Romania 2026: How AI Sees and Recommends Professionals
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