Searching for Answers

In October 2025, following OpenAI’s disclosure that ChatGPT’s search feature had reached an average of 120.4 million monthly users in the EU, a Commission spokesperson confirmed that regulators are currently assessing whether ChatGPT can be designated as a Very Large Online Search Engine. The legal question is whether a service that synthesises answers rather than returning indexed links falls under Digital Services Act as an “online search engine”. The Commission should answer yes. A functional interpretation is legally mandated, economically justified, and urgently necessary.