The EU designates ChatGPT a Very Large Online Search Engine

ChatGPT is now, in the eyes of the European Union, a search engine, and one of the very large ones.

The designation

The European Commission designated ChatGPT a Very Large Online Search Engine under the Digital Services Act on August 31, 2026, the first chatbot placed in that category. The trigger was scale: OpenAI reported about 159.1 million average monthly ChatGPT search users in the EU, far above the 45 million threshold that brings a service under the Act’s strictest tier. Reddit and Roblox were designated Very Large Online Platforms in the same decision.

What it obliges OpenAI to do

Following notification, the designated services have four months, by January 2027, to comply with the additional obligations. Those include assessing and mitigating systemic risks tied to the service and its algorithmic systems, from illegal content and effects on minors to fundamental rights and electoral processes, plus independent audits and data access for researchers. Violations can be fined up to 6% of global annual revenue.

The Commission’s tech chief, Henna Virkkunen, framed it as accountability proportional to reach: the three services “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.”

Why it matters

For years the question of whether an AI chatbot is a search engine was a debate for lawyers and product managers. The Commission has now answered it with a number: at 159 million monthly search users, ChatGPT is regulated like Google Search, whatever it calls itself. The open question is how OpenAI documents systemic risk for answers it generates rather than links it ranks.