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vlose.eu

Questions

Short answers, each traceable to the Regulation or to a Commission decision.

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.
What are the penalties for non-compliance?
Fines of up to 6% of worldwide annual turnover, and periodic penalty payments of up to 5% of average daily worldwide turnover. Three fines have been issued so far, totalling €870 million: X (€120 million), Temu (€200 million) and AliExpress (€550 million).
Can a service lose its designation?
Yes. Where average monthly active recipients fall durably below 45 million, Article 33(5) requires the Commission to withdraw the designation. Stripchat is the only service this has happened to, on 27 May 2025.
Who enforces the DSA against designated services?
The European Commission has exclusive competence over the asymmetric obligations in Articles 34 to 43 for VLOPs and VLOSEs. National Digital Services Coordinators supervise everything else and handle the vetted researcher route.
What is the supervisory fee?
An annual charge under Article 43 that funds the Commission’s supervision, proportionate to a service’s active recipients in the Union and capped at 0.05% of the provider’s worldwide annual net income for the preceding financial year. It is unrelated to compliance and is not a penalty.