VLOP vs VLOSE
The short answer: they are the same regulatory tier applied to two different kinds of service. A VLOP is a very large online platform; a VLOSE is a very large online search engine. The threshold is identical, the obligations are identical, and the Commission enforces both. Only the service being regulated differs.
| VLOP | VLOSE | |
|---|---|---|
| Stands for | Very large online platform | Very large online search engine |
| Defined in | Articles 3(i) and 33 | Articles 3(j) and 33 |
| Threshold | 45 million monthly active recipients in the Union | Identical |
| Designated by | European Commission decision | European Commission decision |
| Compliance starts | Four months after notification | Four months after notification |
| Risk assessment (Art. 34) | Covers feeds, moderation, amplification | Covers ranking and presentation of results |
| Recommenders (Art. 38) | A non-profiling feed option | Non-profiling search results |
| Ad repository (Art. 39) | Required | Required |
| Marketplace duties | Where consumers contract with traders | Not applicable |
| Enforced by | European Commission | European Commission |
| Maximum fine | 6% of worldwide annual turnover | 6% of worldwide annual turnover |
| How many | 25 designated | 3 designated |
Why the distinction exists at all
The DSA is built in layers. Every intermediary service carries a baseline; hosting services carry more; online platforms more again; and designated services carry the asymmetric obligations in Articles 33 to 43. Search engines sit slightly outside that stack — a search engine is not an online platform, because it does not store and disseminate information at the request of its users.
So the legislator ran a parallel track. Wherever the Regulation reaches the very large tier, it names both: "providers of very large online platforms and of very large online search engines". The obligations are written once and applied to both. VLOSE exists as a separate acronym because search needed to be pulled into the tier explicitly, not because it is regulated differently once inside.
The practical consequence shows up in interpretation rather than in text. Article 38's non-profiling requirement means a chronological feed on a platform and unpersonalised results on a search engine. Article 34's risk assessment reaches amplification on one and ranking on the other. The words are the same; the engineering is not.
Can one service be both?
Not as a single designation — each decision names a service and a tier. But a provider can hold several. Google Ireland is the clearest case: Google Search is a VLOSE, while Google Play, Google Maps, Google Shopping and YouTube are each separately designated VLOPs. Five designations, five sets of obligations, one company.
ChatGPT is the interesting edge. The Commission described it as a hybrid service — an AI system that also functions as a search engine — and placed it in the VLOSE tier rather than splitting it. That choice will shape how the next generative service is treated.