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ChatGPT, the AI chatbot made by US company OpenAI, could be subject to the strictest EU platform rules after it said on Tuesday that it now has more than 120 million users per month in Europe, a spokesperson for the European Commission hinted at on Wednesday.
Under the EU’s Digital Services Act (DSA), which aims to combat the spread of illegal content and products online, the largest online platforms face stricter rules than smaller ones due to their significant societal impact, including their potential to spread harmful content and disinformation.
Platforms with more than 45 million users per month, such as Amazon, X, TikTok, and Meta’s Facebook and Instagram, need to meet more transparency reporting obligations and pay higher supervisory fees than others to allow the Commission to keep a closer eye on the measures they take to clamp down on illegal content.
Platforms need to update the EU executive on the user numbers in the 27-member bloc every half year.
OpenAI said in its statement on Tuesday that “for the six-month period ending 30 September 2025, ChatGPT search had approximately 120.4 million average monthly active recipients in the European Union.”
“The figure is a monthly average of EU based users using ChatGPT’s search capability over the past six months and not ChatGPT use as a whole,” the report added.
ChatGPT said in September that it has some 700 million weekly active users globally.
Asked at a press briefing in Brussels on Wednesday, the Commission spokesperson said the EU executive was aware of ChatGPT’s new numbers and that an assessment has begun.
“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 added.
The Commission uses numbers provided by the platforms themselves to determine whether they meet the 45 million-user threshold.
If the chatbot were to be designated as DSA-compliant, it would bring the number of very large online platforms under the rules to 26.
In 2023, the Commission designated the first batch of 19 platforms, including Facebook, Instagram, TikTok, LinkedIn, Amazon and Zalando. It has since designated six other platforms, including e-commerce platforms Temu and Shein.
The EU executive oversees the 25 largest platforms, while all others are under the supervision of national authorities in the member states. Oversight depends on where the companies’ EU headquarters are based.
The Commission began several probes into possible breaches of the DSA, including against TikTok, Facebook, Instagram and AliExpress. None of those investigations has been wrapped up yet.