EU Classifies ChatGPT as a Very Large Online Search Engine
The European Commission has officially classified ChatGPT as a "very large online search engine," subjecting it to the highest level of regulation under the Digital Services Act. This is the first time that an AI conversational service has been categorized as a search engine rather than just a platform under this framework.
The Commission describes ChatGPT as a hybrid service: it can respond to user inquiries and retrieve information from the web, thus constituting an online search engine for regulatory purposes. The provider is OpenAI Ireland Limited, with approximately 159.1 million monthly active users in the EU, far exceeding the 45 million threshold. On the same day, Reddit and Roblox were classified as very large online platforms, with monthly active users of about 57.2 million and 48 million, respectively.
The three services have four months, until the end of November, to fulfill their obligations as very large platforms: annual systemic risk assessments, independent audits, and transparent reporting covering illegal content, protection of minors, mental and physical health, fundamental rights, elections, and public safety. New features must also undergo risk assessments before launch.
OpenAI had previously reported the scale of its search functionality in the EU. This classification does not affect the parallel applicability of the Digital Markets Act and the Artificial Intelligence Act. Existing very large search engines like Google Search are already on the same list, with Ireland being one of the coordinating countries for digital services.
From a market mechanism perspective, the cost is borne by the compliance budget needed to transform the chatbot to meet search engine obligations, while the speed of product iteration is sold without being included in the highest tier. The event is driven by user scale exceeding the threshold and the Commission's classification; funds flow from model revenues to auditing, risk mitigation, and transparency systems. The beneficiaries are regulators who gain oversight tools equivalent to those for Google Search, while the burden falls on companies that must convert conversational generation into auditable search services.
Source: Public Information
ABAB AI Insight
Brussels made a classification decision: chatbots that search for answers online are considered search engines. The platform label governs user-generated content, while the search engine label governs how queries are organized and presented. By placing ChatGPT in the latter category, it means that recommendations, citations, and retrieval paths must be reported based on systemic risk rather than just model safety.
The capital pathway is to front-load compliance costs. The 159 million monthly active users in the EU push OpenAI from the "innovation sandbox" onto the same oversight table as Google and Bing. The four-month window requires piling up materials for audits, protection of minors, and election risks. Money flows from subscriptions and APIs into legal and trust safety teams, with an additional evaluation gate before product features go live. Ireland continues to act as the coordinating country, with fines and procedures still following the very large tier of the Digital Services Act.
The benchmarks are Google Search and Bing being labeled as very large search engines, while TikTok and Meta are labeled as very large platforms. AI is at a stage where "conversational interfaces swallow search boxes": users no longer open a search engine first, but regulation extracts the search function separately from chat. The simultaneous entry of Reddit and Roblox into the platform tier indicates that the Commission is filling two nets on the same day: generative retrieval and user-generated worlds.
Structurally, this belongs to regulatory change. The mechanism is: as queries shift from ten blue links to a generated answer, risks expand from ranking bias to hallucinations, citations, and conversations with minors. The classification decision precedes technical terminology. It is permissible to call it a chatbot, but it is regulated as a search engine. Whoever crosses the 45 million threshold first enters the annual audit.
ABAB News · Cognitive Law
Conversations that can retrieve will be regulated as search engines.
Once user scale crosses the threshold, classification takes precedence over product terminology.
Generated answers replace blue links; the risk list will only grow longer, not shorter.