The European Commission designated ChatGPT a Very Large Online Search Engine under the Digital Services Act on August 31, alongside Reddit and Roblox as Very Large Online Platforms. All three declared at least 45 million average monthly EU users, the threshold that triggers the DSA’s strictest tier of obligations, and ChatGPT is the first AI chatbot to receive the search engine designation. The three companies have four months, until January 2027, to comply.
Very Large Online Search Engine status requires ChatGPT to run systemic risk assessments covering illegal content, effects on minors, users’ physical and mental well-being, fundamental rights, and electoral processes, the same regime Google Search and Bing already operate under. For a platform simultaneously building out ChatGPT Ads, adding geo-targeting, custom audiences, an OpenAI Pixel, and expanding to 31 more European markets this same month, the designation lands at an inconvenient moment: a business trying to scale ad inventory across Europe now also carries the EU’s heaviest platform compliance load, arriving as generative interfaces push further into workflows once owned by search boxes and CRMs alike. See Salesforce’s own bet that the CRM interface itself is now optional and the IAB’s rewritten rules for disclosing AI inside ads.
Brussels’ framing effectively treats a chat interface the same as a results page, which sets a precedent every other AI assistant with an ads roadmap will eventually have to answer to. The designation does not target ChatGPT Ads directly, but any conversational surface that scales past 45 million EU users now inherits search-engine-grade risk-assessment duties before it inherits search-engine-grade ad revenue, a sequencing problem no rival chatbot with ad ambitions can avoid once it hits the same threshold.
Source: European Commission
