The EU is flexing its regulatory muscles again, and this time ChatGPT is in the crosshairs. According to Handelsblatt, Brussels is actively examining whether to classify OpenAI and ChatGPT as “very large search engines” under the Digital Services Act (DSA)—a reclassification that would trigger a cascade of new obligations.

This matters because the DSA’s rules for very large search engines are substantially stricter than baseline platform requirements. We’re talking algorithmic transparency, content moderation duties, and data sharing obligations that go far beyond what a typical tech company faces. If OpenAI gets tagged as a VLASE (very large online platform), they’re in for a world of compliance pain.

Why now? The DSA already requires platforms above a certain user threshold to publish monthly active recipient statistics. OpenAI has been doing that—showing their EU user numbers over the past six months. But the EU is looking at the data and seeing something that looks an awful lot like a search engine: people input queries, getting algorithmically ranked results, expecting answers. Whether you call it “search” or “conversation” is almost semantic when the function is the same.

This isn’t just about OpenAI. It’s part of a broader EU strategy to bring AI products under existing regulatory frameworks where they can, rather than waiting for the AI Act’s full enforcement in August. The AI Act has its own risk-based approach, but the DSA is live now—and regulators are finding ways to use it.

OpenAI has declined to comment, which is either strategic silence or genuine uncertainty about where this goes. Either way, this adds another layer to operating in the European market. The AI Act is coming with its compliance requirements. The DSA might pile on more. It’s starting to feel like the EU is threading the needle between innovation and control, and AI companies are finding out just how control-heavy it gets.

For OpenAI, the choice narrows: comply, fight, or potentially restrict EU access. Given the market size, “comply” is likely—but compliance won’t be cheap or simple.