Brussels designates ChatGPT as a very large online search engine

On 31 August 2026 the European Commission designated ChatGPT as a very large online search engine under the Digital Services Act. The announcement also concerns Reddit and Roblox, which like ChatGPT have declared that they exceed the size threshold set by the regulation. The news is published by the Representation in Italy of the European Commission and picked up by the German public broadcaster Tagesschau.

It is a story the morning edition did not cover, and it concerns a technical distinction with practical consequences. The European regulation provides for two categories of entities subject to the most stringent obligations: platforms and search engines. ChatGPT has been placed in the second, that of search engines, not the first. In which of the two categories Reddit and Roblox have been placed, the available excerpts do not specify, and this newspaper does not infer it.

The threshold

The criterion that triggers the designation is quantitative: at least 45 million average monthly active users in the European Union. All three services declared that they exceed it. The figure declared by OpenAI, however, is much higher than that threshold: according to Tagesschau, the company’s transparency report for 2025 indicated over 120 million users in the Union, almost three times the regulatory limit.

The designation is neither a sanction nor the outcome of an investigation: it is the application of a category to a service that has exceeded a size threshold declared by the service itself. The mechanism of the regulation works this way — it is the companies that publish their own user numbers, and the Commission draws the consequences.

The timeline

The designated services have four months to comply with the additional obligations set out in the regulation. The Commission indicates January 2027 as the deadline. On what these obligations specifically entail for a service of this kind — and on how a discipline written for traditional search engines applies to a conversational system — the available excerpts contain no clarification, and this newspaper adds none.

It is worth noting the value of the precedent: it is the first time, as far as the documents used here show, that the category of very large search engines has been applied to a service based on a language model. The classification does not stem from a judgment on the content produced, but from the function performed and the size of the user base.

This piece’s method

The two sources used share the same origin — the Commission’s announcement — but Tagesschau adds an independent element, the figure from OpenAI’s transparency report for 2025, which does not appear in the institutional press release. The declared number of users remains information provided by the company concerned, not a third-party measurement: it is reported as a declaration, not as a verified fact.

What we do not know

No reaction from OpenAI, Reddit or Roblox is known. We do not know the number of users declared by the other two companies, nor the category to which they were assigned, nor the reasoning by which the Commission deemed ChatGPT a search engine rather than a platform. It does not appear, in the available excerpts, whether an appeal against the designation is planned or has been announced. The operational deadline remains the one indicated by the Commission: January 2027.