Regulation · European Union
Digital Services Act (DSA) — ChatGPT VLOSE requirements
The European Commission designated ChatGPT a Very Large Online Search Engine under the Digital Services Act, bringing it under enhanced requirements for assessing and reducing systemic risks from its service and algorithmic systems. The designation adds independent audits, researcher data access and direct Commission supervision. The Commission’s notice sets January 2027 as OpenAI’s deadline to comply with the additional requirements.
- In force
Updated
What it requires
- Assess systemic risks from the service and its algorithmic systems, including effects on minors, well-being, fundamental rights, elections and public security.
- Put measures in place to mitigate identified systemic risks.
- Provide readable, multilingual terms and conditions.
- Maintain a crisis-response mechanism.
- Undergo independent audits.
- Provide researchers access to publicly accessible data without undue delay and meet data-access obligations for vetted researchers studying systemic risks.
Who it affects
OpenAI must comply with the additional requirements applicable to ChatGPT as a designated Very Large Online Search Engine in the EU.
Timeline
The European Commission designated ChatGPT a Very Large Online Search Engine, triggering additional DSA obligations and direct Commission supervision. Our story