The EU now treats ChatGPT like a giant search engine, so its ads will need a public trail

ChatGPT Search is more than three times over the EU threshold

Brussels no longer sees ChatGPT Search as a minor feature tucked inside a chatbot. The European Commission has designated it a very large online search engine, the Digital Services Act category for services reaching at least 45 million monthly users in the European Union. Reddit and Roblox were designated very large platforms at the same time.

OpenAI reported 159.1 million average monthly active recipients for ChatGPT's online search features over the six months ending March 31, 2026. That number does not cover every use of ChatGPT, but it is more than triple the threshold. The company now has four months, until the end of December 2026, to meet the extra obligations.

This is the missing half of the story we covered yesterday about ChatGPT opening self-service advertising in Europe. Selling ads is no longer just a commercial rollout because each campaign will sit inside a much stricter transparency and oversight framework.

A public record of who paid for each ad

Designated services must assess and mitigate systemic risks, undergo yearly independent audits and provide data to vetted researchers. When a search product writes the answer instead of presenting ten links, users need to know where each claim came from and when a company paid to appear. Without those signals, a sponsored recommendation can look like a neutral conclusion.

The DSA also requires a public advertising repository showing what ran, who paid, how long it remained active and which targeting criteria were used. Journalists, researchers and users should be able to trace political, financial or commercial campaigns delivered through ChatGPT. The archive cannot stop a deceptive campaign on its own, but it will leave a public trail for later scrutiny.

The designation is oversight, not a ban

VLOSE status is not a fine and does not declare ChatGPT's answers unlawful. It recognizes that the search engine is large enough to create systemic effects, so OpenAI must document how it handles illegal content, children, public health, elections, fundamental rights and public security.

Audits cannot guarantee that every failure is caught before users see it, but they change who must explain the system and who can demand evidence. That distinction matters after OpenAI disbanded its Preparedness team: European scrutiny no longer depends entirely on the company's internal structure.