WHY THIS MATTERS
The European Commission designated ChatGPT as a Very Large Online Search Engine under the Digital Services Act (DSA) on August 31, 2026, the first time an AI chatbot has received that classification. OpenAI reported about 159.1 million average monthly users of ChatGPT's search function in the EU, well above the 45 million threshold that triggers the rule. The company has four months to meet systemic risk assessment and independent audit obligations, according to the European Commission, Search Engine Journal and Business Standard.In this article
CONFIRMED
The European Commission designated ChatGPT as a Very Large Online Search Engine under the Digital Services Act (DSA) on August 31, 2026, making OpenAI's chatbot the first AI assistant to receive that classification. The decision was officially announced by the European Commission and confirmed by outlets including Search Engine Journal, Heise, Business Standard and Winbuzzer.
Why ChatGPT became a very large search engine
The DSA requires the Commission to classify as a very large search engine any service that surpasses 45 million average monthly active users in the European Union. OpenAI reported that ChatGPT's search function had about 159.1 million average monthly active users in the EU over the six month period ending March 31, 2026, more than three times the threshold that triggers the rule. Because ChatGPT can search the web and answer based on those results, the Commission classified it as a hybrid service that also functions as a search engine.
What changes for OpenAI
OpenAI has four months from the designation to meet the DSA's additional obligations for very large services: assessing and mitigating systemic risks tied to the spread of illegal content, effects on minors, users' physical and mental well being, fundamental rights, electoral processes and public security, plus undergoing independent audits and opening data to researchers. It is the same regime already applied to giants like Google Search and Bing.
A pattern that repeats
ChatGPT's designation did not come alone: in the same batch of decisions, the Commission also classified Reddit and Roblox under the DSA, widening the belt of digital services subject to tougher transparency and safety rules in the European Union. For the Commission, the criterion is always the same: scale. Once a service concentrates tens of millions of monthly users in Europe, it stops being treated as just another tool and starts carrying the responsibility of critical information infrastructure.
Why it matters for Brazilian agencies and SMBs
The rule only applies to the European Union, but it tends to preview what other regulators, including Brazil's, are likely to copy once the AI legal framework finally comes to a vote. Agencies and SMBs that use the ChatGPT API or recommend the tool to clients get, in practice, a preview of the transparency and audit standard that major generative AI platforms will need to sustain globally. It is worth tracking how OpenAI documents this compliance process, since systemic risk reports and external audits tend to become a best practice reference even outside Europe.
Sources
European Commission, Commission designates ChatGPT, Reddit, Roblox under Digital Services Act: https://digital-strategy.ec.europa.eu/en/news/commission-designates-chatgpt-reddit-roblox-under-digital-services-act | Search Engine Journal, ChatGPT Is Now A Very Large Online Search Engine In The EU: https://www.searchenginejournal.com/chatgpt-is-now-a-very-large-online-search-engine-in-the-eu/587801/ | Business Standard, What does the EU very large search engine tag mean for ChatGPT: https://www.business-standard.com/world-news/what-does-the-eu-very-large-search-engine-tag-mean-for-chatgpt-126090100678_1.html