EU puts ChatGPT under its 45M-user rule

The European Commission designated ChatGPT a Very Large Online Search Engine after OpenAI reported at least 45 million average monthly EU users, the threshold in its DSA designation notice. ChatGPT now has four months, until January 2027, to assess and mitigate systemic risks involving illegal content, minors, wellbeing, rights, elections, and public security. Builders serving EU users should file this as a product-governance deadline, not a distant platform-policy label: risk evidence and mitigation ownership now belong in launch checklists, as the EU AI Act’s separate transparency deadlines already demonstrate.