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The EU just decided ChatGPT is a search engine

2–3 min read

On August 31, the European Commission designated ChatGPT a Very Large Online Search Engine under the EU’s Digital Services Act, putting ChatGPT in the same regulatory category as Google Search and Bing.

The platform now has until January 2027 to comply with the heaviest tier of DSA obligations.

At Parvi, we think the interesting word in the announcement is “search engine“.

Whether ChatGPT is “really” a search channel has been a topic of debate. Buyers clearly use it like one, and the referral traffic shows up in analytics, but plenty of teams still treat AI visibility as an experiment they will look at later, or something that “can’t really be tracked”

What OpenAI has to do by January: assess and mitigate systemic risks from the service and its algorithms, submit to independent yearly audits, publish a searchable ad repository, open data access to vetted researchers, and pay a supervisory fee. Fines can reach 6% of global turnover, and the Commission has already fined AliExpress, Temu and X under the DSA.

The designation changes nothing in how ChatGPT retrieves or cites content today. But it does give EU officials some access to the platforms operating model and likely an increase in visibility to the platform later on.

Two things we think are likely going to happen because of this (and overall EU) regulatory changes:

  • A public ad archive. ChatGPT ads went live in 31 European countries on August 24, non-personalized, Free and Go tiers. An archive in the style of Meta’s Ad Library would show you who advertises in ChatGPT in your category, with what creative.
  • EU ChatGPT diverging from US ChatGPT. Compliance work tends to make products more conservative in the regulated market, and possibly more heavily sourced. More citations would be good news for anyone whose content is worth citing.

How this will impact content retrieval and what types of content gets displayed remains to be seen.

If you would like to know how your company currently shows up in ChatGPT, and what you could do differently to get even more out of the platform, book a call with our growth strategist.

Otso Karvinen

Co-founder & Growth Strategist

I help marketing and sales teams do more in a month than their competitors do in a quarter. With 15+ years in marketing and sales, I now help build agentic AI systems that let small teams deliver faster and better results. I’m easy to work with and happy to have a no-strings conversation about where you are and how I and our team at Parvi can help.

Read more about Otso Karvinen

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