The European Commission has taken a significant step in regulating online services by designating ChatGPT as a search engine under the Digital Services Act. This move brings ChatGPT, along with Reddit and Roblox, under the Act's regulatory framework as Very Large Online Platforms.
ChatGPT, the first AI chatbot to be designated under this regime, reported 159 million monthly active users across the six months to March 2026, far exceeding the 45 million monthly user threshold set by the DSA. Reddit and Roblox also cleared this threshold, with 57.2 million and 48 million monthly users, respectively.
The decision to treat ChatGPT as a search engine raises interesting questions, as it generates answers rather than simply retrieving and ranking web pages. This distinction matters, as the DSA imposes different requirements depending on the type of service being designated.
As a result of this designation, ChatGPT, Reddit, and Roblox will be required to conduct annual systemic risk assessments covering areas such as illegal content, protection of minors, and fundamental rights. They will also be subject to independent audits and must provide access to data for regulators and vetted researchers.
The companies will have four months to comply with these new requirements, with a deadline set for the end of November. Failure to comply can result in fines of up to 6% of a company's global annual turnover for serious violations.
For Roblox, which has a significant portion of its audience made up of children and teenagers, the requirements around minors are particularly significant. The company will need to formally assess and mitigate risks to their safety and wellbeing, with these measures subject to independent auditing.
OpenAI, the developer of ChatGPT, faces a different set of challenges. Its assessment will need to address systemic risks around electoral processes and public security, among other areas. This will require translating broad concerns about the influence of AI on people at scale into identifiable, measurable, and auditable risks.
The designations also have a specific legal anchor, applying to named entities rather than just consumer-facing brands. OpenAI Ireland Limited, Reddit Netherlands B.V., and Roblox Corporation are listed in the Commission's register, with national regulators in Ireland and the Netherlands sharing enforcement responsibilities with the Commission.
This decision comes as European technology enforcement is becoming more active across several fronts. Poland has asked the Commission to fine Meta €250 million over scam advertising, while the Commission is preparing measures to require Google to open Android to rival AI assistants under the Digital Markets Act.
Neither OpenAI, Reddit, nor Roblox has publicly challenged the designations, although they can appeal the decisions. The broader significance of this move is that the DSA is now being applied beyond social networks and content platforms, bringing a chatbot, an online forum, and a platform used by children under the same regulatory framework.
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