On August 31, 2026, the Commission ChatGPT under the Digital Services Act as Very Large Online Search Engine classified, abbreviated VLOSE. What initially sounds like dry legalese is actually a minor watershed moment for the entire industry. A European regulatory authority is thus officially recognizing what many search engine optimizers have long felt: ChatGPT ticks like a search engine, and your clients are now using it in the exact same way, with real research queries instead of mere playfulness. Anyone who has only had eyes for Google until now should look more closely at the latest now, because the rules of attention are shifting noticeably under the hood, even if everything still looks the same on the surface.
Why the EU is now officially classifying ChatGPT
The classification follows fixed rules that have been known for years and is not a spontaneous whim of the Commission. Anyone who reaches more than 45 million average monthly users in the EU automatically falls under the strictest category of the Digital Services Act, which has previously been reserved almost exclusively for established giants such as Google, Bing, or large social networks. According to European Commission OpenAI reported 159.1 million active users in the EU alone to the authority, while ChatGPT itself now has over one billion weekly users worldwide across all platforms. The threshold was thus exceeded many times over, and it was precisely this clarity that ultimately made the classification a formality.
With this classification, ChatGPT lands in the same category as Google Search and Bing, with practically identical obligations. By the way, on the same day, Reddit and Roblox were also classified as very large online platforms, albeit under a different category of the law, a sign of how quickly AI services are now crossing the relevant user thresholds. For OpenAI, this means annual risk assessments regarding disinformation, fundamental rights, and electoral interference, independent audits by external reviewers, transparency reports every six months, a dedicated contact person for the authorities, and a new labeling requirement, much like the one already for EU AI Act, which brings its own disclosure obligations for AI-generated content starting in August. The deadline for this is four months from the official notification, realistically pushing full implementation to January 2027, and violations threaten, according to Gizmodo Fines of up to six percent of global annual turnover, a magnitude that would noticeably hurt even a corporation like OpenAI.
What the classification means for your visibility
Legally, nothing will change for your company and your ongoing campaigns for now, because the new obligations apply exclusively to OpenAI as the operator of the platform. Strategically, however, the matter is still highly relevant, and indeed immediately rather than just by the implementation deadline next year. If an authority officially classifies ChatGPT as a search engine, the argument loses, Generative Engine Optimization is just a hype for a few early adopters, finally its foundation. GEO has thus firmly arrived in everyday marketing, with the same demands on care, budget, and systematic approach as classic SEO, as well as our Post detailing SEO in the context of ChatGPT with concrete figures on daily search volume.
What actually works in this channel has Ahrefs recently investigated through a broad-based analysis of 75,000 brands, all of which featured solid search volume and a certain level of domain strength, thus qualifying as representative of the SME sector. Brand mentions on the open web correlate significantly more strongly with AI visibility—with values between 0.66 and 0.71—than classical backlinks, which in the same analysis achieve a weak 0.20, a factor that many budgets have completely misweighted so far. Mentions on YouTube have the strongest impact, clearly ahead of specialized articles, industry forums, and traditional press releases. Anyone who has previously invested primarily in traditional link building would do well to read these figures twice and carefully reallocate their next content budget accordingly, without completely crossing traditional SEO off the plan just yet.
What specifically changes for advertisers and brands
Currently, ChatGPT does not display ads in the EU, but the new transparency requirements are already laying the technical and legal groundwork for future ad formats. In our experience, a clear mandatory labeling rule for ads on other major platforms was often the first step, long before ad formats were even introduced. OpenAI is likely to take this exact path as well, especially since monetizing such a massive and continuously growing user base is economically likely just a matter of time. For brands and agencies, it is therefore worthwhile to take a close look at the practical consequences of this classification today, rather than reacting frantically shortly before the deadline in January.
- Annual risk assessments regarding disinformation, fundamental rights, and potential electoral interference through generated responses. The findings flow directly into future moderation guidelines.
- Independent audits by external testing bodies, the core results of which will be publicly accessible in the future and provide genuine insight into how the system works for the first time.
- Transparency reports every six months providing insight into moderation practices and the handling of reported content, comparable to the reports Google has long since published.
- A reporting interface for illegal content, similar to the one that has been established at Google and Bing for some time and gives users a direct way to complain.
- Prepared ad labeling that makes subsequent ad formats in the EU noticeably more likely and is likely to affect media budgets in the long term.
How to align your strategy now
Visibility in ChatGPT takes time, systemics, and more than a single clever trick. It demands the same consistency that you already know from traditional SEO, just with different levers, new metrics, and some unfamiliar KPIs that many teams still need to get used to. Anyone who starts making their brand consistently visible across various sources, channels, and platforms now will secure a tangible head start before the competition even wakes up. Large Language Model Optimization belongs in every strategy meeting from now on, and anyone who wants to delve into the technical fundamentals at their leisure will find them in our Guideline found information on LLM SEO with practical examples.
- One llms.txt set up so that language models can capture your most important content cleanly, in a structured way, and without detours. This is technically quick to implement and takes hardly any developer time.
- Targeted and lasting promotion of brand mentions in trade articles, industry forums, and especially on YouTube, instead of leaving them to chance. According to current data, this is precisely where the biggest lever lies.
- Clearly structure content and consistently think in a question-and-answer logic so that answers can be directly cited and do not first have to be laboriously pieced together.
- E-E-A-TSharpening signals, meaning making experience, expertise, authoritativeness, and trustworthiness visible and backing them up with real evidence, such as through author profiles and source citations.
- Regularly check, document, and share visibility in ChatGPT, Perplexity, and Google AI Overviews with the team so that successes remain measurable.
FAQs about ChatGPT as a search engine
What does VLOSE mean in ChatGPT?
VLOSE stands for Very Large Online Search Engine. With this, the EU classifies services with more than 45 million monthly users in the EU as requiring special regulation, just like Google Search and Bing before them. ChatGPT clearly reaches this threshold with around 159 million users in the EU alone, placing it well above the limit.
As of when do the new obligations apply to OpenAI?
OpenAI has four months from the official notification to implement all requirements. Realistically, this means full implementation by January 2027, including risk assessments, independent audits, and regular transparency reports.
What is the difference between SEO and GEO?
SEO optimizes content for classic search results with rankings, Snippets and clicks on blue links. GEO aims to be cited as a source or actively recommended in the responses of generative AI systems like ChatGPT, regardless of traditional ranking on a results page.
Will there be ads in ChatGPT soon?
According to the current status, ChatGPT does not show ads in the EU. However, the new transparency obligations for ad labeling are already creating the regulatory basis for this, which in our experience is often the first step before the launch of own ad formats.
How can you improve your visibility in ChatGPT?
According to current data, broad brand mentions across various channels, a clean technical foundation such as an llms.txt, and well-structured content that is easy to cite are important. Backlinks alone are long from being sufficient for this; what is crucial is the brand's presence across the entire web.
