> ## Content Index > Fetch the complete content index at: https://hoeijmakers.net/llms.txt > Use this file to discover other available public pages before exploring further. # Europe Has Decided ChatGPT Is a Search Engine - URL: https://hoeijmakers.net/europe-has-decided-chatgpt-is-a-search-engine/ - Published: 2026-09-01T17:46:17.000Z - Updated: 2026-09-01T17:46:17.000Z - Description: The EU has designated ChatGPT a Very Large Online Search Engine. The decision exposes the uneasy hybrid inside one product: public information infrastructure and private working environment. - Author: Rob Hoeijmakers - Tags: Europe, AI Governance I use ChatGPT every day. I do not personally use **ChatGPT Search**. I knew the feature was there, but regarded it as an annex to the product. For me, ChatGPT was primarily a working environment: somewhere to think, write, analyse, organise information and increasingly interact with other systems. If it could also search the web, that was useful, but not central to how I understood it. Yesterday’s regulatory development has made that view harder to maintain. On 31 August, the European Commission designated ChatGPT a Very Large Online Search Engine under the Digital Services Act. I initially read this as a regulatory fact about ChatGPT Search. The search feature had grown beyond the DSA threshold, so Europe was applying its rules for very large search engines. The Commission’s fuller explanation is more interesting. It describes ChatGPT as a **hybrid service** which qualifies as an online search engine because it can respond to users’ prompts and queries, including by searching the web. Europe has not designated a separate product called ChatGPT Search. It has designated ChatGPT. ## How much of ChatGPT is now a search engine? The answer appears to be both broader and less absolute than the headline suggests. OpenAI reports that [ChatGPT search had approximately 159.1 million average monthly active recipients](https://help.openai.com/en/articles/8959649-eu-digital-services-act-dsa) in the European Union during the six months ending 31 March 2026\. That is comfortably above the DSA threshold of 45 million. Search supplied the numbers. But the Commission designated the service as a whole, reasoning that ChatGPT’s ability to search the web makes it a hybrid service that qualifies as an online search engine. It also says it can investigate the functionalities behind ChatGPT and, where relevant, related systems. [The designation therefore appears broader](https://ec.europa.eu/commission/presscorner/detail/en/ip%5F26%5F1772) than a neat regulatory boundary around search results alone. That does not mean every ChatGPT answer has legally become a search result. It does not automatically make the OpenAI API, Codex or every other OpenAI product a VLOSE. Nor does it necessarily mean that every ChatGPT plan and function will be treated identically. The detailed designation decision has not yet been published, so the exact perimeter remains unclear. But the named service is ChatGPT, not merely its Search button. ## One product, two different logics This exposes something about ChatGPT that I had not fully accounted for. On one side, it is becoming **a mass-market information service**. It offers broad free or low-cost access, retrieves and synthesises public information, recommends options and increasingly occupies moments that previously belonged to conventional search engines. OpenAI is also developing advertising inside its Free and Go tiers. Ads have not yet been introduced generally across the European Union, but the commercial direction is visible: free access supported partly by advertising, with paid tiers remaining ad-free. On the other side, ChatGPT is **a paid professional tool**. Plus and Pro users pay for more capable personal use. Business and Enterprise customers treat it as part of their working environment, with organisational controls, connected sources and different contractual expectations. Search is available there too, but it is one capability within a much broader system. These are materially different product logics gathered under the same name and interface. One resembles a public information service funded by reach, subscriptions and potentially advertising. The other resembles professional infrastructure sold on capability, control and trust. The DSA designation did not create this structure. It has made the structure legally consequential. If the consumer information service and professional work environment genuinely form one hybrid service, regulatory scrutiny may reach across the shared systems behind them. If OpenAI considers them materially separate, it may increasingly need to define and defend that boundary. ## What has not happened Nothing in the designation says ChatGPT will be banned or stripped of features in Europe. A VPN is not a meaningful response to anything that has actually occurred. Organisations using ChatGPT have not suddenly acquired new DSA obligations either. The additional duties fall on OpenAI. Within four months, the company must comply with requirements concerning systemic risk assessment, mitigation, transparency and independent auditing. Much of that could remain behind the product. Some of it might eventually become visible. We cannot yet know. The important development is more fundamental. Europe is no longer treating ChatGPT solely as an AI system or a software tool. It is treating it as **information infrastructure with effects that need to be systematically accounted for**, including effects on minors, wellbeing, fundamental rights, political processes and public security. A few weeks ago, I wrote about how [the AI Act changed while it was arriving](https://hoeijmakers.net/eu-ai-act-changed-while-arriving/). My conclusion was that understanding the technology increasingly requires understanding the regulatory machinery developing around it. This designation goes a step further. It has changed how I understand the product itself. Until yesterday, I saw search as an annex to the ChatGPT I actually use. Europe has effectively said that the annex is significant enough to determine the regulatory category of the building. We do not yet know what OpenAI will change, or whether European users will notice anything different in January. But I can no longer describe ChatGPT simply as a professional AI tool that happens to include search. It has become a hybrid of public information infrastructure and private working environment. That makes both the product and its regulation more difficult to separate into tidy parts.