The European Commission on August 31, 2026, designated ChatGPT a Very Large Online Search Engine under the Digital Services Act, making OpenAI's chatbot the first standalone AI service subjected to the bloc's highest tier of platform regulation2,3,7. Reddit and Roblox were designated the same day as Very Large Online Platforms.
All three services crossed the 45 million monthly active EU user threshold that triggers direct Commission oversight. ChatGPT reported 159.1 million monthly active users in the EU over the six-month period ending March 2026. Reddit reported 57.2 million, and Roblox roughly 48 million over the same period.
The Commission classified ChatGPT as a "hybrid service" that qualifies as an online search engine "because it can engage with and respond to users' prompts and queries, including by searching the web". Under the designation, OpenAI is subject to the same DSA obligations faced by Google and Bing in Europe.
The three companies now have four months, until the end of November, to conduct annual systemic risk assessments covering illegal content, minor protection, mental and physical wellbeing, fundamental rights, electoral processes, and public security. They must also submit to independent audits and share data with regulators and vetted researchers. The services will be required to explain to users why content is recommended, offer opt-outs from profiling-based feeds, and maintain content moderation systems with rights to appeal.
The DSA also restricts designated platforms from targeting ads to minors or using a person's sexual orientation, religion, ethnicity, or political beliefs for ad targeting8. Non-compliance carries penalties of up to 6% of global annual turnover.
The Commission said it now has the power to impose crisis response measures during emergencies and demand rapid changes to platform operations. The EU's Internal Market Commissioner described the move as "a necessary step to ensure that platforms with systemic reach are held accountable for illegal content, threats to fundamental rights, public security, and risks to minors".
OpenAI must identify and assess systemic risks linked to how its model generates and surfaces content, including evaluating potential harms to civic discourse, electoral processes, and public health. The company will need to open its systems to external auditing and publish detailed transparency reports on content moderation decisions and algorithmic processes.
The DSA has already produced roughly €870 million in fines to date, including €550 million against AliExpress, €200 million against Temu, and €120 million against X.
ANALYSIS The classification of ChatGPT as a search engine rather than simply a platform reflects a regulatory judgment that AI chatbots with web-retrieval capabilities function as information gatekeepers comparable to traditional search engines. This places OpenAI's compliance burden on par with established search incumbents in Europe, requiring systemic risk assessments and algorithmic transparency mechanisms that the company has not previously been obligated to provide under EU law.
The designation arrives as ChatGPT's footprint continues to expand across government and consumer contexts. The U.S. Department of Defense recently added ChatGPT Mil to its GenAI.mil portal, extending access to 3 million personnel ctx.