EU Designates ChatGPT as Very Large Online Search Engine After Crossing 45 Million Users

The European Commission on Monday designated OpenAI’s ChatGPT as a Very Large Online Search Engine under the Digital Services Act, after the chatbot declared that it reaches at least 45 million average monthly users in the European Union.

In the same decisions, Brussels classified Reddit and Roblox as Very Large Online Platforms, bringing the total number of designated very large platforms and search engines to 28.

Crossing 45 million monthly users, about one in ten people in the EU, is the statutory trigger for enhanced supervision. ChatGPT, Reddit and Roblox were already bound by the DSA’s general rules for platforms and search engines.

Designation adds a heavier layer. Following notification, they have four months, until the end of January 2027, to assess and mitigate systemic risks from their services and algorithmic systems.

Those assessments must cover illegal content, harm to minors, users’ physical and mental well-being, fundamental rights, electoral processes and public security.

Independent annual audits and researcher data access will now sit alongside those risk reports, giving vetted specialists a much clearer window into how the designated systems actually behave at European scale.

The ChatGPT decision matters because of the legal box Brussels chose. As detailed in the European Commission’s official decision, the Commission described the chatbot as an artificial intelligence system that answers prompts and queries, including by searching the web, and therefore as a hybrid service that qualifies as an online search engine.

That is a first for conversational AI. It places ChatGPT alongside established search engines, with duties on ranking transparency, independent audits, and data access for regulators and vetted researchers.

For teams tracking AI-enabled influence operations, the message is that a chatbot retrieving web-scale answers for tens of millions of Europeans is now treated as critical search infrastructure.

Reddit and Roblox were designated as platforms because they let users disseminate third-party content to the public. Reddit is a discussion service organized around topic-based communities.

Roblox is an immersive gaming and creation environment where users publish and play games built by others.

Both models create content-moderation and child-safety exposure, so the extra risk assessments now attach to their recommendation systems as well as to user-generated material.

The Commission now has investigative powers over the functionalities behind these services and, where relevant, related systems.

Supervision will be shared with national Digital Services Coordinators: Ireland’s Coimisiún na Meán for ChatGPT and Reddit, and the Netherlands Authority for Consumers and Markets for Roblox. Non-compliance can attract fines of up to 6 percent of global annual turnover.

Henna Virkkunen, Executive Vice-President for Tech Sovereignty, Security and Democracy, said ChatGPT, Reddit and Roblox will be held to a higher standard of scrutiny and accountability, in line with their impact on citizens and society.

She added that Brussels will keep watching the digital landscape and will not hesitate to designate any platform that meets the threshold.

For security teams, conversational AI with live search, large forums and user-generated game worlds are no longer at the edge of Europe’s platform law. They are inside it, with a deadline in January 2027.

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