On August 31, the European Commission designated ChatGPT a “Very Large Online Search Engine” under the Digital Services Act — the first AI chatbot ever pulled into the DSA’s toughest tier. Reddit and Roblox were designated the same day, but as platforms. ChatGPT stands alone in the search engine box.
The numbers that triggered it
The DSA threshold is 45 million monthly EU users. ChatGPT search reported 159.1 million — 3.5x over the line. OpenAI now has four months, until end of January 2027, to assess and mitigate systemic risks: illegal content, minors’ protection, mental health, elections. That means independent audits, data access for researchers, and Commission supervision. Miss the bar and fines run up to 6% of global revenue.
The legal label matters more than the fine
The Commission’s reasoning: ChatGPT takes your question and goes out to find the answer, therefore it’s a search engine. That one sentence sets the regulatory path for every AI chatbot — Gemini, Claude, and Perplexity all do exactly the same thing. And OpenAI didn’t fight it. A spokesperson confirmed ChatGPT search “operates as a search service under the DSA.” When the biggest player accepts the label, the precedent is locked in for everyone else.
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