ChatGPT’s 120 Million EU Users Trigger “Very Large Platform” Status Under Landmark DSA Law
OpenAI’s ChatGPT is on the verge of being classified as a “Very Large Online Platform” (VLOP) by the European Union, a move that would subject the popular AI chatbot to the bloc’s most stringent digital regulations under the landmark Digital Services Act (DSA).
The trigger for this significant shift is user growth. OpenAI recently disclosed that the “search” feature of ChatGPT alone averaged 120.4 million monthly users in the EU over a six-month period. This figure far surpasses the DSA’s key threshold of 45 million monthly users, which designates a platform as a VLOP, requiring the highest level of regulatory oversight.
A European Commission spokesperson confirmed the milestone, stating, “We are aware of ChatGPT’s new numbers and that an assessment has begun.” This formal assessment is the first step toward potentially imposing a new, rigorous compliance framework on OpenAI.
What VLOP Status Means for ChatGPT and Its Users
If officially designated, ChatGPT would join the ranks of tech giants like TikTok, X (formerly Twitter), and Meta’s Instagram and Facebook, which are already under the DSA’s VLOP regime. This classification brings a suite of demanding obligations designed to mitigate systemic risks and enhance user safety.
For ChatGPT, this could translate into:
Enhanced Transparency: OpenAI would be forced to provide detailed disclosures about its algorithms, data usage, and content moderation processes.
Systemic Risk Assessments: The company would need to rigorously assess and report on potential risks linked to its AI, including the spread of disinformation, generation of illegal content, and impacts on fundamental rights.
Stricter Oversight and Fees: OpenAI would face more frequent auditing, mandatory reporting to the European Commission, and be liable to pay substantial supervisory fees.
User Protections: Users in the EU could see new safeguards around data handling, more transparent options for flagging AI-generated content, and potentially more controlled feature rollouts to ensure compliance.
A New Frontier for AI Regulation
The potential inclusion of ChatGPT under the DSA marks a pivotal moment in digital governance. It signals that EU regulators are viewing powerful generative AI tools not as niche applications, but as mainstream platforms with significant societal impact. The DSA, one of the world’s most ambitious digital laws, was designed to hold large online services accountable for their role in shaping public discourse and digital safety.
This move reflects a growing consensus that the vast reach and algorithmic nature of AI chatbots make them a focal point for regulatory action. The combination of high user engagement and the potential for AI to amplify harmful content aligns directly with the DSA’s core objectives.
The Road Ahead for OpenAI
For OpenAI, VLOP status would usher in a new era of compliance in its second-largest market. The company would need to navigate a complex web of reporting obligations across the EU’s 27 member states, incur significant compliance costs, and likely adapt its product development lifecycle to meet regulatory expectations.
While this could lead to a slower rollout of new features in Europe, it also promises a more transparent and accountable AI ecosystem for users. The ongoing assessment by the European Commission will be crucial; its conclusion in the coming weeks or months will definitively shape how one of the world’s most influential AI services operates within the EU.
In short, ChatGPT’s user growth is not just a commercial success—it’s a regulatory turning point. As the EU’s regulatory machinery engages, OpenAI must prepare for a future where its innovative technology operates under the world’s most robust digital rulebook.
