The European Commission has classified ChatGPT as a "very large online search engine" under the Digital Services Act (DSA), marking the first time an AI chatbot has received this regulatory designation. Reddit and Roblox have been designated as very large online platforms. All three services, which each reach at least 45 million monthly users in the European Union, now face the bloc's most stringent digital safety requirements and have until the end of November to comply.

Why Is ChatGPT Being Treated Like a Search Engine?

The European Commission's decision to classify ChatGPT as a search engine rather than simply a platform represents a significant regulatory shift. The Commission described ChatGPT as a "hybrid service" that qualifies as an online search engine under the DSA because it can engage with user prompts and queries, including by searching the web for live results. This distinction matters because it subjects ChatGPT to obligations traditionally reserved for search engines like Google, not just social platforms.

OpenAI disclosed that ChatGPT's search function averaged approximately 159 million monthly active users in the EU during the six months ending March 2026, far exceeding the 45 million threshold that triggers "very large" designation. Reddit reported 57.2 million monthly users in the EU, while Roblox reported roughly 48 million.

"These new designations mean that ChatGPT, Reddit and Roblox 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," stated Henna Virkkunen, executive vice-president for tech sovereignty, security and democracy.

Henna Virkkunen, Executive Vice-President for Tech Sovereignty, Security and Democracy, European Commission

What New Obligations Do These Platforms Face?

The four-month compliance window is tight, and the obligations are comprehensive. Under the DSA, very large platforms and search engines must conduct annual systemic risk assessments covering multiple areas of potential harm. These assessments must address the dissemination of illegal content, protection of minors, effects on users' mental and physical wellbeing, impacts on fundamental rights, electoral processes, and public security.

Beyond risk assessments, the three services must also submit to independent audits and share data with regulators and vetted researchers. The European Commission will supervise compliance with support from Ireland's Coimisiún na Meán for ChatGPT and Reddit, and the Netherlands' Authority for Consumers and Markets (ACM) for Roblox.

Steps These Platforms Must Take to Comply

• Risk Assessment: Conduct comprehensive annual reviews identifying and mitigating risks related to illegal content, minor protection, user wellbeing, fundamental rights, electoral integrity, and public security.
• Independent Audits: Submit to third-party audits verifying compliance with DSA obligations and allowing regulators to assess the functionality and design of their services.
• Data Sharing: Provide regulators and approved researchers with access to platform data necessary for oversight and investigation of potential violations.
• Transparency Measures: Implement systems to track and report on content moderation decisions, algorithmic recommendations, and user safety protections.

What Are the Financial Consequences of Non-Compliance?

The stakes are substantial. Non-compliance with DSA obligations can result in fines of up to 6 percent of a company's global annual turnover. For OpenAI, which has experienced rapid revenue growth, such penalties could prove particularly costly. The DSA has already generated approximately 870 million euros in fines across various platforms, including a record 550 million euro penalty against AliExpress in July 2026 for failing to curb illegal and counterfeit goods sales.

The regulatory environment reflects the EU's broader commitment to holding large digital services accountable. The Commission stated it will "continue to watch the digital landscape closely and will not hesitate to designate any platform that meets the threshold for enhanced supervision under the Digital Services Act". With these three designations, the total number of platforms and search engines under the DSA's strictest tier now reaches 28.

The Commission

How Might This Affect US-EU Tech Relations?

The designations have already drawn criticism from Washington. The Trump administration previously called DSA fines on Apple and Meta a "novel form of economic extortion" and threatened retaliation against countries with digital rules targeting US tech firms. With three more American-owned services now under direct Commission supervision, such rhetoric could intensify, potentially escalating tensions between US technology companies and European regulators.

For ChatGPT, Reddit, and Roblox, the next four months will be critical. They must demonstrate meaningful progress on risk mitigation, data transparency, and user protection to avoid substantial penalties. The EU's willingness to classify an AI chatbot as a search engine signals that regulators worldwide are actively developing frameworks to oversee AI systems as they become more integrated into everyday digital life.