EU weighs ChatGPT oversight

European Union regulators are weighing whether ChatGPT belongs under the bloc’s toughest online-service rules after OpenAI disclosed user numbers above the legal threshold. (digital-strategy.ec.europa.eu, globalbankingandfinance.com) The European Commission said on April 10 it was analyzing whether ChatGPT should be treated as a large online search engine under the Digital Services Act. OpenAI’s European Union filing said ChatGPT search averaged about 120.4 million monthly active recipients in the six months ending September 30, 2025. (globalbankingandfinance.com, help.openai.com) Under the Digital Services Act, services with more than 45 million monthly users in the European Union can be designated as very large online platforms or very large online search engines. Once designated, a service has four months to comply with the stricter rules. (digital-strategy.ec.europa.eu) Those rules go beyond basic notice-and-takedown systems. The Commission says very large services must assess systemic risks tied to illegal content, fundamental rights, public security, elections, public health, minors, and mental and physical wellbeing, then report and mitigate those risks. (digital-strategy.ec.europa.eu) The case turns on a legal question the European Union did not have to answer when it wrote the law in 2022: whether a chatbot that can search the web should be treated like a search engine, a platform, or both. European Parliament members raised that issue in a written question to the Commission in December 2025. (europarl.europa.eu) That distinction affects what OpenAI would have to do in practice. Politico reported in November 2025 that the Commission was considering whether to limit any designation to ChatGPT’s search function or apply it to the broader service. (politico.eu) OpenAI has already published a Digital Services Act contact point for authorities and says its reported figure was calculated solely for compliance with the law. The company’s help page says the 120.4 million figure covers ChatGPT search in the European Union, not the full chatbot service. (help.openai.com) ChatGPT is also entering a second European rulebook at the same time. Politico reported that general-purpose artificial intelligence models face obligations under the European Union’s Artificial Intelligence Act from August 2026, while Digital Services Act duties would focus on the service’s reach and online-system risks. (politico.eu) Euractiv reported in February 2026 that the Commission had aimed to finish the designation process by the first quarter of 2026. As of April 10, the Commission was still describing the review as an active assessment rather than a final decision. (euractiv.com, globalbankingandfinance.com) For OpenAI, the immediate issue is not whether ChatGPT is popular in Europe; its own filing already answered that. The next step is whether Brussels decides that popularity puts ChatGPT inside the Digital Services Act’s top tier. (help.openai.com, digital-strategy.ec.europa.eu)