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European Union flag over a laptop displaying ChatGPT, symbolizing new audit rights and search engine regulations.

Editorial illustration for EU Gains Audit Rights Over ChatGPT Under New Search Engine Rules

EU Classifies ChatGPT as Search Engine, Gains Audit Rights

4 min read

Brussels has a new label for OpenAI's chatbot, and it's not one the company chose. The European Commission announced Monday that ChatGPT will be classified as a very large search engine under the Digital Services Act, a designation triggered by its web-search function and a user base that tops 45 million people across the EU each month. That number matters: it's the exact threshold the DSA sets for the strictest tier of oversight, the same category Google Search has occupied for years.

Reddit and Roblox got their own reclassification the same day, moved into the "very large online platform" bucket because both let users post and share content. All three companies now have until the end of December 2026, four months from the announcement, to fall in line with obligations that include risk assessments covering illegal content, harm to minors and election interference. Irish and Dutch regulators will work alongside the Commission to enforce the new rules, which also hand Brussels expanded audit powers over how these services operate.

The EU Commission is classifying ChatGPT as a very large search engine for the first time, putting the chatbot under stricter oversight rules. The Commission announced the move Monday in Brussels.

Why this matters

The four-month clock OpenAI, Reddit, and Roblox now face is worth watching closely, because it tests whether the EU's platform rulebook actually bends to fit a chatbot with a search function bolted on, or whether the fit is forced. Classifying ChatGPT alongside search engines rather than social platforms is a judgment call about what the product is for, and 45 million EU users was apparently enough to trigger it. For developers building on top of OpenAI's stack, the practical stakes are the ad archive, researcher data access, and twice-yearly transparency reports, none of which are free to produce and all of which invite outside scrutiny of how ChatGPT actually behaves.

For founders elsewhere in the EU market, the message is that user-count thresholds matter more than product category, so growth itself can trigger a regulatory reclassification. We'd watch whether OpenAI contests the "search engine" label or just complies, since that answer will tell other AI companies how much room they have to argue about definitions before Brussels decides for them.

Common Questions Answered

Why did the European Commission classify ChatGPT as a very large search engine under the Digital Services Act?

The European Commission classified ChatGPT as a very large search engine because it has a web-search function and exceeds 45 million monthly active users across the EU, which is the exact threshold that triggers the strictest tier of oversight under the Digital Services Act. This classification puts ChatGPT in the same regulatory category as Google Search, subjecting it to stricter EU oversight requirements.

What is the significance of ChatGPT reaching 45 million EU users according to the Digital Services Act?

The 45 million monthly active users across the EU is the exact threshold specified in the Digital Services Act that triggers classification as a very large online platform subject to the strictest oversight tier. This user count milestone was the determining factor that caused the European Commission to reclassify ChatGPT under the most stringent regulatory requirements rather than less restrictive categories.

How much time does OpenAI have to comply with the new EU oversight rules for ChatGPT?

OpenAI, along with Reddit and Roblox, faces a four-month deadline to comply with the stricter oversight rules established under the Digital Services Act. This timeline will test whether the EU's platform rulebook can effectively apply to a chatbot with an integrated search function.

What is the practical impact of ChatGPT being classified as a search engine rather than a social platform?

Classifying ChatGPT as a search engine rather than a social platform represents a judgment call about the product's primary function and determines which regulatory framework applies to it. This classification decision affects developers building on OpenAI's stack and establishes precedent for how the EU regulates AI tools with search capabilities.

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