Insight

Is ChatGPT now a search engine? What the EU’s VLOSE designation means for brands

21 September 20269 min readNew Brand Media

Yes. For the purposes of the EU Digital Services Act, ChatGPT is now officially a Very Large Online Search Engine (VLOSE). The additional obligations fall on OpenAI as the service provider, not on brands using ChatGPT or investing in GEO and AEO. The practical significance for brands is this: AI-generated answers are now firmly part of search, not a side experiment.

On 31 August 2026, the European Commission designated ChatGPT as a VLOSE after OpenAI reported about 159.1 million average monthly active recipients in the EU for ChatGPT search, its online search features, over the six months to 31 March 2026. The VLOSE threshold is 45 million. The Commission described ChatGPT as a hybrid service because it can respond to prompts and search the web.

That decision puts ChatGPT in the same DSA service category as Google Search and Bing. It does not turn every ChatGPT response into traditional search, and it does not make brands responsible for OpenAI's regulatory duties. It does give businesses a useful external signal: buyers increasingly discover, compare and assess companies through AI answers, and the infrastructure behind those answers is being treated accordingly.

Is ChatGPT officially a search engine in the EU?

ChatGPT is officially classed as an online search engine under the Digital Services Act because its capabilities include searching the web in response to users' questions. The Commission calls it a hybrid service: it remains a generative AI system, but part of what it does meets the DSA definition of online search.

The designation is not a marketing label. It is a legal classification applied to OpenAI Ireland Limited after the service crossed the DSA scale threshold.

Official fact	What the EU says
Designation	Very Large Online Search Engine (VLOSE)
Designated service	ChatGPT
Provider in the EU	OpenAI Ireland Limited
EU users reported	About 159.1 million average monthly active recipients for ChatGPT search (six months to 31 March 2026)
VLOSE threshold	At least 45 million average monthly EU users
Designation date	31 August 2026
Compliance timetable	Four months following notification, by January 2027

Source: European Commission VLOP and VLOSE register, updated 31 August 2026.

Google Search and Bing have held VLOSE status since 2023. ChatGPT is different because search is one capability inside a conversational AI service, rather than the whole product. That distinction matters. The Commission did not decide that all chatbots are search engines. It decided that ChatGPT's web-search functionality, scale and role meet the relevant test.

What is a Very Large Online Search Engine?

A Very Large Online Search Engine is an online search service that reaches at least 45 million average monthly users in the EU. Under the Digital Services Act, services at this scale face additional oversight because problems in their systems can affect a substantial part of the public.

Following designation, OpenAI has four months to meet the additional VLOSE obligations. The Commission highlights requirements to assess and mitigate systemic risks connected with illegal content, minors, physical and mental well-being, fundamental rights, electoral processes and public security.

These are obligations for the platform. They concern how the service and its algorithmic systems are governed, assessed and supervised. They are not a new compliance checklist for a company trying to appear in an AI answer.

This article is general information about the designation and its relevance to digital visibility. It is not legal advice.

What does ChatGPT's VLOSE status mean for businesses?

The direct legal effect falls on OpenAI. The commercial signal reaches further.

When buyers ask ChatGPT for a shortlist, an explanation or a recommendation, they are using an answer interface that may retrieve, rank and summarise information from the web. The EU's decision recognises that search function at the regulatory level. Businesses should therefore treat AI answers as part of their discoverability work, alongside conventional search.

That does not mean abandoning SEO. ChatGPT, Google AI Overviews, Gemini and Perplexity all depend on information they can retrieve and evaluate. Clear pages, consistent company facts, named sources, useful internal linking and credible mentions remain foundational.

The practical change is in the question businesses ask. Instead of asking only, "Where do we rank on Google?", they should also ask:

Does an AI answer name the company for the questions buyers actually ask?
Does it describe the company accurately?
Which sources does it cite?
Are the company's services, locations and proof consistent across those sources?
Can an answer engine extract a clear, factual response from the website?

Those are GEO and AEO questions, but they are also basic questions about brand authority.

Does the Digital Services Act create new GEO or AEO rules for brands?

No. ChatGPT's VLOSE designation does not create a new legal requirement for brands to optimise content for AI search.

It also does not guarantee that structured data, a particular page format or a new piece of content will change how ChatGPT describes a business. Search and answer systems make their own retrieval and ranking decisions.

What the designation does is remove some of the ambiguity around the category. ChatGPT can be conversational software and perform an online-search function at the same time. For marketing teams, that supports a sensible operating assumption: AI visibility belongs in the search and brand measurement plan, even though the platform's legal obligations belong to OpenAI.

Other AI assistants may attract similar scrutiny if their capabilities and EU reach meet the relevant tests. That is a possibility, not a confirmed designation. A durable GEO strategy should therefore avoid dependence on one platform and focus on information that is accurate, attributable and useful wherever buyers search.

How does this change SEO, GEO and AEO?

It strengthens the case for treating them as one connected discipline.

SEO helps pages become discoverable and understandable in conventional search. Answer Engine Optimisation (AEO) gives direct questions clear, extractable answers. Generative Engine Optimisation (GEO) improves the chances that a brand and its evidence can be retrieved, understood and cited in generated responses.

The labels are less important than the shared work:

Shared requirement	What good looks like
Clear answers	The first paragraph answers the question without a long preamble
Consistent entity facts	Name, services, location and expertise agree across the web
Evidence	Claims link to primary sources, original work or named proof
Structure	Useful headings, summaries, tables and FAQs help people and machines scan
Authority	Independent mentions reinforce what the company says about itself
Measurement	Teams track citations and answer accuracy as well as rankings and traffic

This is why chasing "GEO hacks" is the wrong response. A schema block cannot repair vague positioning. Repeating a keyword cannot create evidence. Publishing ten near-identical AI articles will not make a company easier to trust.

For an organisation working in professional services, finance, healthcare or another high-trust sector, accuracy matters as much as visibility. Being mentioned in an AI answer is not a win if the answer gets the service, location or credentials wrong.

What should brands do now?

Start with a small, measurable AI-search visibility audit.

Choose five to ten buyer questions. Use real questions from sales calls, proposals and search data, not phrases invented solely for volume.
Record the baseline. Check whether the company is absent, mentioned or cited across the answer engines that matter to its buyers.
Check accuracy. Note incorrect services, stale facts, missing locations and unsupported claims.
Map the evidence. Identify which pages and third-party sources could support a better answer.
Improve the answer pages. Lead with a clear response, cite primary evidence and link naturally to the relevant service.
Re-run the same questions. Measure change on a consistent prompt set after the content has had time to be crawled.

New Brand Media applies this approach through its Digital Marketing & Conversion Design work: SEO, GEO, AEO and conversion design treated as one system rather than separate retainers.

The aim is not to make a brand appear everywhere. It is to make the right information available, credible and quotable when a buyer asks a relevant question.

Frequently asked questions

Why did the EU classify ChatGPT as a search engine?

The Commission says ChatGPT is a hybrid service because it can answer prompts and search the web. OpenAI reported about 159.1 million average monthly active recipients in the EU for ChatGPT search. That is above the 45 million VLOSE threshold.

Is ChatGPT in the same category as Google Search?

Under the Digital Services Act, ChatGPT, Google Search and Bing are designated Very Large Online Search Engines. Their products work differently, but they share that DSA service classification.

When must OpenAI comply with the additional VLOSE obligations?

The European Commission says the designated services have four months following notification, meaning by January 2027.

Does this mean businesses must optimise for ChatGPT?

No law requires a business to optimise for ChatGPT. Commercially, businesses should decide whether their buyers use AI answers and whether the information returned about them is accurate. If that channel matters, it belongs in the visibility plan.

Will GEO replace SEO?

No. AI answer systems still rely on retrievable, credible information. Strong technical SEO, useful content, consistent brand facts and independent authority support both conventional search and AI visibility.

Next step

The short version: ChatGPT is officially a Very Large Online Search Engine under the EU Digital Services Act, but the new legal obligations apply to OpenAI; for brands, the designation is evidence that AI answers now belong in the search visibility plan.

Do not respond by publishing more generic AI copy or buying a renamed SEO package. Start by checking what answer engines say about the business today, which sources they rely on and which buyer questions return no useful result.

Book a free call and you will speak to Jonathan Porter, not a salesperson. If you would rather start in writing, ask a question and we will reply within four working hours. No obligation. No hard sell.