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2025-01-01

Question of the Day

Question of the day · 2026-08-31 ·

One question per day to look beyond the headlines.

How does labeling ChatGPT a “very large online search engine” change which DSA duties it must operationalize?

Take-away “VLOSE” status shifts ChatGPT into a systemic-risk regime: it must run auditable risk-assessment→design-change loops plus regulator data access, not just moderate content.

Labeling ChatGPT as a "Very Large Online Search Engine" under the EU Digital Services Act (DSA) imposes stricter duties related to content moderation, transparency, and risk mitigation [2], [3]. As a Very Large Online Search Engine, ChatGPT must now comply with enhanced obligations to mitigate systemic risks, including managing illegal content, ensuring the well-being of minors, safeguarding fundamental rights, and protecting public security [1], [4]. This includes conducting risk assessments, implementing design changes, performing annual audits, maintaining an internal compliance program, providing a public ad library, and granting data access to regulators [2]. Failure to meet these duties could result in penalties, potentially up to 6% of global annual revenue [2], [5].

Sources · 2026-09-01