ChatGPT Is Now A “Very Large Online Search Engine” In The EU via @sejournal, @MattGSouthern
ChatGPT is now a very large online search engine under the EU Digital Services Act after OpenAI reported about 159.1 million average monthly search recipients. The post ChatGPT Is Now A “Very Large Online Search Engine” In The EU...
FrankLin
The European Commission designated ChatGPT as a very large online search engine under the Digital Services Act, making it the first AI chatbot to receive the designation.
The Commission announced its decision today, along with two other designations. Reddit and Roblox are now recognized as very large online platforms, each with at least 45 million average monthly users in the EU, meeting the threshold for the designation.
What The Designation Requires
The three services have four months from notification to meet the extra rules the DSA sets for its largest platforms and search engines.
What ChatGPT’s DSA designation triggers
OpenAI’s EU disclosure put ChatGPT search above the DSA threshold. ChatGPT has four months from notification to comply with the additional DSA obligations.
Average monthly active recipients in the EU
≥45M threshold
≈159.1M reported
ChatGPT search average monthly active recipients in the EU; six months ending March 31, 2026. The OpenAI figure is approximate and was calculated solely for DSA compliance.
Designation
Very large online search engine
August 31, 2026
Compliance window
4 months
Four months from notification to comply with additional DSA obligations.
Additional obligations
Systemic-risk controls
Identify, assess, and mitigate risks tied to the service and its algorithmic systems.
Independent audits
Undergo an independent audit at least once a year and respond to the auditor’s recommendations.
Regulator and researcher access
Share data with the Commission and national authorities, and allow vetted researchers access for qualifying systemic-risk research.
Recommenders and ads
Where applicable, offer a recommender option not based on profiling and maintain a public ad repository.
Important: Designation is not a finding of wrongdoing. Enforcement is a separate process.
They need to identify and reduce the systemic risks associated with their services and algorithmic systems. The Commission’s list includes concerns about illegal content, negative effects on minors, users’ mental and physical wellbeing, fundamental rights, electoral processes, and public security.
Each service must also be audited by an outside auditor every year, share data with the Commission and national authorities, and open platform data to vetted researchers. Services that use recommender systems must offer an option that doesn’t rely on profiling, and services that show ads must keep a public archive of them.
The designation also allows the Commission to take a closer look at the systems behind each service. That doesn’t make it a finding of wrongdoing. Enforcement procedures are handled separately, and if rules are broken, fines can be as high as 6% of a company’s global annual revenue.
Why ChatGPT Counts As A Search Engine
The Commission described ChatGPT as a hybrid service that qualifies as an online search engine because it responds to users’ prompts and queries, including by searching the web.
The individual figures come from the companies’ own DSA disclosures rather than the release. OpenAI reported that ChatGPT search had approximately 159.1 million average monthly active recipients in the EU over the six months ending March 31, 2026, more than three times the threshold. Reddit reported no more than 57.2 million monthly users for the first half of 2026, and Roblox estimated its average at 46.6 million.
Henna Virkkunen, the Commission’s executive vice-president for tech sovereignty, security and democracy, said:
“These new designations mean that ChatGPT, Reddit and Roblox will now be held to a higher standard of scrutiny and accountability in the European Union, in line with their large impact on our citizens and society.”
The decision extends a question I’ve tracked through the EU’s Google proceedings this year. In April, I covered the Commission’s proposal to make Google share search data with rivals under the Digital Markets Act. The binding version arrived in July. The DMA and the DSA are separate laws. Under the July decision, chatbots with search functions can qualify for access to Google’s search data if they meet the DMA’s definition of an online search engine. Today’s decision goes further and designates ChatGPT itself.
Why This Matters
This designation clarifies ChatGPT’s role under the DSA, where the Commission now sees it as an online search engine because it can answer questions and search the web. The figure of around 159.1 million is OpenAI’s DSA count of average monthly active recipients for ChatGPT search in the EU. Over time, the transparency rules could become just as important as the label itself, especially as vetted researchers will have a legal avenue to request platform data for studying systemic risks.
Looking Ahead
The compliance deadline is just four months away from today’s notification, and soon after, the first systemic risk reports will be submitted to the Commission. If a service stays below 45 million monthly EU users for a whole year, the Commission has the authority to revoke its designation.
Enforcement puts the label to the test, as seen with the Commission’s DSA fines, which have reached a total of 870 million euros, including 550 million euros against AliExpress back in July. One of the biggest questions is how the Commission will apply these same rules to a chatbot in the coming year.
Featured Image: Teodora ART/Shutterstock
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