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Commission designates ChatGPT under EU platform rules, with new obligations from January 2027

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10 September 2026

Commission designates ChatGPT under EU platform rules, with new obligations from January 2027

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The photo presents keyboard keys spelling “AI” through a tear in brown paper.

The European Commission has designated ChatGPT as a Very Large Online Search Engine (VLOSE) under the Digital Services Act, after the service confirmed it reaches at least 45 million average monthly users in the EU, meaning it must comply with additional transparency and risk-assessment obligations from January 2027.

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European Commission

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EU-27

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Company with 250 or more employees

Industry Associations and Chambers of Commerce

SMEs (a company with less than 250 employees)

  • Ecosystem

    • Retail

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Under the DSA, VLOSE status brings enhanced obligations, including assessing and mitigating systemic risks arising from the service and its algorithmic systems, covering areas such as the spread of illegal content, effects on minors, users' physical and mental wellbeing, fundamental rights, electoral processes and public security. The designated service has four months from notification to bring itself into compliance.

As AI-based search and conversational assistants take on a growing role in how consumers discover and compare products, retailers relying on such tools as a channel to reach shoppers may see downstream effects from the stricter transparency and risk-mitigation requirements now applying to ChatGPT under EU platform law. The Commission maintains a public list of all platforms and search engines designated under the DSA for ongoing supervision.

#DigitalMarketsAct #AIinRetail

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