EU Eyes ChatGPT for Strict Rules After User Surge

ChatGPT Crosses Major User Threshold in Europe

The popular AI chatbot ChatGPT, developed by US-based OpenAI, is now under the regulatory spotlight in the European Union. The company announced this week that it has surpassed 120 million average monthly users in the region, a milestone that could trigger the EU's most stringent platform regulations.

According to a transparency report released by OpenAI, the platform saw approximately 120.4 million average monthly active users in the EU for the six months ending in September 2025. The company clarified that this figure specifically reflects users engaging with ChatGPT's search capability, not the total usage of the entire service. This number is a significant portion of its global user base, which the company previously reported as around 700 million weekly active users worldwide as of September.

What is the Digital Services Act

The European Union's Digital Services Act (DSA) is a landmark piece of legislation designed to create a safer online environment by tackling the spread of illegal content and disinformation. The law imposes a tiered system of obligations, with the strictest rules reserved for 'Very Large Online Platforms' (VLOPs)—those with more than 45 million monthly active users in the EU.

These major platforms are subject to enhanced scrutiny due to their significant societal impact. Their obligations include more rigorous transparency reporting, proactive measures to clamp down on harmful content, and paying higher supervisory fees to fund the European Commission's oversight activities. Platforms are required to report their EU user numbers every six months to determine if they meet this threshold.

European Commission Begins Assessment

Following OpenAI's announcement, a spokesperson for the European Commission confirmed on Wednesday that the executive body is aware of ChatGPT's latest user numbers and has initiated an assessment. While an official designation has not been made, the spokesperson acknowledged that the AI chatbot could potentially fall within the scope of the DSA's highest tier of regulation.

“It could potentially be in the scope of the DSA, [an analysis] this has to be done on a case by case basis,” the spokesperson stated during a press briefing in Brussels. The Commission relies on the user data provided by the platforms themselves to make these critical designations.

A Growing List of Regulated Platforms

If ChatGPT is officially designated as a VLOP, it will join an expanding list of 25 other major tech platforms already under the DSA's strictest rules. The initial group of 19, designated in 2023, included giants like Meta's Facebook and Instagram, TikTok, Amazon, X (formerly Twitter), and LinkedIn.

Since then, six more platforms have been added, including popular e-commerce sites Temu and Shein. The European Commission is directly responsible for overseeing these 25 VLOPs, while smaller platforms are supervised by national authorities. The Commission has already launched several investigations into potential DSA breaches by companies such as TikTok, AliExpress, Facebook, and Instagram, though none of these probes have concluded.