By considering classifying ChatGPT as a very large search engine, the European Commission would shift the focus of the Digital Services Act. Designed to regulate the public circulation of third-party content, the DSA could become an instrument for supervising private conversational architectures. This would be a major legal shift, and a highly political one at that. According to our colleagues at Contexte, the prospect of ChatGPT being designated under the Digital Services Act in the fall of 2025 is no longer hypothetical: « The European Commission is certain to supervise ChatGPT on behalf of the DSA, possibly as early as this spring. It has yet to decide whether it is a very large platform or a search engine (VLOP or VLOSE), » writes Guénaël Pépin today. If this hypothesis were to be confirmed, it would raise important legal questions. On the one hand, bringing ChatGPT within the scope of the DSA would imply a particularly…
