European Commission Designates ChatGPT a Very Large Online Search Engine

The European Commission has designated ChatGPT as a very large online search engine under the Digital Services Act (DSA), the European Union (EU) law that imposes extra obligations on the largest platforms. It is the first AI chatbot to receive that designation. Reddit and Roblox were designated on the same day under the parallel rules for very large online platforms.

The trigger was OpenAI's own reporting. The company disclosed that ChatGPT search averaged 159.1 million monthly active recipients in the EU over the six months ending 31 March 2026, well above the 45 million threshold in the law. The Commission characterized ChatGPT as a hybrid service that qualifies as a search engine because it answers user queries partly by searching the web.

The obligations are concrete. Designated services must run annual systemic risk assessments, submit to independent audits, give researchers data access, offer a recommender option not based on profiling, and publish transparency reports. The companies have four months from notification to comply, a deadline the Commission places in January 2027, and penalties reach 6 percent of global annual turnover.

There is an unresolved technical question underneath the legal one. Systemic risk assessment and auditing methods were written for ranked link lists and feeds, not for generated answers where the output is produced fresh for each query. Auditing a model's answer distribution is a different measurement problem than auditing a ranking, and neither the Commission nor the auditing firms have published a method for it.