The EU Just Classified ChatGPT as a Search Engine, and That Changes What It Owes You

The European Commission announced on Monday that it has designated ChatGPT as a Very Large Online Search Engine under the Digital Services Act. Reddit and Roblox were designated at the same time as Very Large Online Platforms. It is the first time an AI chatbot has been pulled under this particular rulebook, and for anyone in the EU who uses ChatGPT, it means the service now has legal duties it did not have last week.

The trigger is a number. Under the DSA, any online platform or search engine that reaches at least 45 million average monthly users in the EU falls into a stricter tier of supervision, run directly by the Commission rather than by national regulators. All three services declared that they cross that line. The Commission counts ChatGPT as a search engine because it is a hybrid service: it responds to prompts and queries, including by searching the web, which is enough to fit the DSA’s definition. The three now have four months, until January 2027, to comply with the additional obligations.

What those obligations actually are. The DSA does not tell a company what its product must say. It tells the company to look for systemic risks in its own service and algorithms, and to do something about them. The named risk areas are concrete: the spread of illegal content, harm to minors, effects on users’ physical and mental wellbeing, fundamental rights, elections, and public security. In practice that means annual risk assessments, independent outside audits, sharing data with regulators and vetted researchers, and a transparency report. Non-compliance can cost up to 6% of global annual revenue.

Here is what is genuinely new about applying this to a chatbot. Every service designated so far, from Google Search to TikTok, mostly shows you content that someone else made. ChatGPT generates the answer itself. So a rulebook written around “how does this platform amplify other people’s content” now has to be applied to a system that writes the content. Nobody has done that before, and the first audit cycle will effectively decide what the rules mean in practice. Expect argument.

What this means for you. Nothing changes in the product today, and nothing you do needs to change. Over the next year or so, if you are in the EU, you should see more visible reporting channels, clearer explanations of how the system works, and published transparency reports. Researchers should get access to data that has been closed until now, which is how independent evidence about these systems eventually gets built. If you are curious rather than technical, the useful takeaway is smaller and more interesting: a regulator has now officially decided that asking a chatbot a question is close enough to searching. A fair caveat, though: designation is the beginning of a process, not a result. The real test is what the first audits find, and those are more than a year away.

Sources

• Commission designates ChatGPT, Reddit, Roblox under Digital Services Act (European Commission)
• Full press release, IP/26/1772 (European Commission)
• EU places ChatGPT, Reddit and Roblox under strictest digital safety rules (Euronews)