Regulation (EU) 2022/2065 · Article 33
A VLOSE is a very large online search engine.
It is the European Union's designation, under the Digital Services Act, for a search service used by at least 45 million people a month in the Union — roughly one European in ten. Designation is not a label. It moves the service into the DSA's heaviest supervisory tier, enforced directly by the European Commission, with fines reaching 6% of worldwide turnover.
Three services currently hold it: Google Search, Bing and — since 31 August 2026 — ChatGPT, the first generative AI assistant brought inside the regime.
The three designated VLOSEs
Every service in this tier was designated by a Commission decision naming it individually. The VLOP tier is far larger — 25 platforms — but the search tier is where the regime's boundaries are currently being tested.
Google Search
VLOSEThe largest designated search engine in the Union and one of the two VLOSEs named in the Commission’s first designation round.
364 million · designated 25 April 2023
Bing
VLOSEMicrosoft’s search engine, designated in the first round on 119 million declared monthly users in the Union.
119 million · designated 25 April 2023
ChatGPT
VLOSEThe first generative AI assistant designated under the DSA. The Commission treats it as a hybrid service and regulates it in the search engine tier.
159.1 million · designated 31 August 2026
What designation actually requires
Articles 33 to 43 of the DSA contain the asymmetric obligations — duties that apply only to designated services. They bite four months after the designation decision is notified.
Most recent designations
Enforcement is no longer theoretical
For the first two years of the regime nothing was decided. That ended in December 2025. Three non-compliance decisions now stand, totalling €870M.
The largest DSA penalty issued to date.
The second non-compliance fine under the DSA.
The first non-compliance decision adopted under the DSA.
Common questions
- What does VLOSE stand for?
- VLOSE stands for very large online search engine. It is the European Union’s designation, under Article 33 of the Digital Services Act, for a search engine with at least 45 million average monthly active recipients in the Union.
- How is a VLOSE different from a VLOP?
- Only the service type differs. A VLOP is a very large online platform, a VLOSE is a very large online search engine, and both are designated on the same 45 million user threshold and carry the same obligations in Articles 34 to 43. The duties are simply read against a ranking and results surface rather than a content feed.
- Which services are designated as VLOSEs?
- Three: Google Search and Bing, both designated on 25 April 2023, and ChatGPT, designated on 31 August 2026.
- Why is ChatGPT regulated as a search engine?
- The Commission treats ChatGPT as a hybrid service. It is an AI system, but users put queries to it and it can retrieve from the open web, which brings it within the Article 3(j) definition of an online search engine — a service that lets users input queries to search, in principle, all websites and returns results in any format.
- What is the 45 million user threshold?
- It is roughly 10% of the Union’s population, and it is measured in average monthly active recipients in the Union averaged over six months. Providers publish the figure themselves under Article 24(2); the Commission designates on the basis of it. The threshold can be adjusted by delegated act if the Union population moves 5% or more from its 2020 level.
- How long does a designated service have to comply?
- Four months from notification of the designation decision, under Article 33(6). For the services designated on 31 August 2026 — ChatGPT, Reddit and Roblox — that falls at the end of December 2026.