OpenAI says on its EU Digital Services Act page, read on 29 October 2026, that “For the six-month period ending 30 September 2026, ChatGPT search had approximately 185.6 million average monthly active recipients in the European Union”.
By our arithmetic, that is about 4.1 times the 45 million average monthly recipients that mark a very large online search engine under the DSA, and about 54% more than the 120.4 million Reuters reported for the six months to September 2025.
A vertical news Short narrated from the headlines and opening lines of this piece and three related pieces.
Business Pill · Distribution Advantage
An evergreen Business Engineer explainer on distribution as a competitive advantage. It teaches the general idea only and does not discuss ChatGPT search or the DSA.
The key insight: By our arithmetic, ChatGPT search now sits at about 4.1 times the DSA’s 45 million line in the EU, while its gain over the prior disclosure has shrunk from about 79.1 million to about 26.6 million.
OpenAI says OpenAI Ireland Limited publishes the figure “In accordance with our obligations under Article 24(2) of the DSA” and that it is “calculated over a six-month period”.
The page adds that “This average has been calculated solely for the purposes of complying with our DSA obligations and should not be relied upon or used for other purposes”. It is an average of monthly recipients over six months, not a count of unique people.
ChatGPT search average monthly active recipients in the EU by six-month period: 11.2M and 41.3M (TechCrunch), 120.4M (Reuters), about 159M (Le Tribunal du Net) and 185.6M (OpenAI, to 30 September 2026). Gains over each prior disclosure and the 4.1x ratio to the DSA 45M threshold are our arithmetic.
A Bigger Base, Smaller Additions
TechCrunch reported in April 2025 that ChatGPT search had roughly 41.3 million average monthly active recipients for the six months ending 31 March 2025, up from about 11.2 million in the earlier disclosure. Reuters reported about 120.4 million for the six months to end-September 2025.
Le Tribunal du Net reported that OpenAI declared about 159 million for the six months ending March 2026. By our arithmetic, the gain over the prior disclosure went from about 79.1 million (to September 2025) to about 38.6 million (to March 2026) to about 26.6 million in the latest six months, a rise of about 17% on the ~159 million.
Inside the DSA’s Top Tier
Le Tribunal du Net reported that on 31 August 2026 the European Commission designated ChatGPT a very large online search engine, a label it said only Google Search and Microsoft Bing had carried until then, and that an OpenAI spokesperson said the company was preparing for the additional compliance requirements.
TechCrunch described the obligations for services above 45 million average monthly recipients as letting users opt out of recommendation systems and profiling, sharing certain data with researchers and authorities, and performing external auditing.
The Search Traffic Around It
Reddit told shareholders on 29 October that “During October, we have seen that search traffic has dropped by more than 1 million referrals on average per week”, and that its daily users could fall by a low-double-digit percentage in the fourth quarter if the decline continues.
Alphabet’s third-quarter 10-Q, as covered in our earlier piece, shows paid clicks on Google Search & other up 8% year on year after 13% in each of the first two quarters of 2026. None of these sources links Reddit’s or Google’s trends to ChatGPT search.
The Structural Read
As we read OpenAI’s page, the figure is an average of monthly recipients over six months, which OpenAI says is calculated only for DSA compliance; it is not a count of unique people or of searches.
As we read the series, the audience is still growing, by about 17% on the roughly 159 million Le Tribunal du Net reported for the six months ending March 2026, while the gain over the prior disclosure has shrunk in each of the last two periods.
As we read Reddit’s letter and Alphabet’s 10-Q, both describe changes in search traffic this autumn; neither names ChatGPT search, and we do not link them.
OpenAI, EU DSA page
“This average has been calculated solely for the purposes of complying with our DSA obligations and should not be relied upon or used for other purposes.”
Three Implications
FOR OPENAI Le Tribunal du Net reported that ChatGPT was designated a very large online search engine on 31 August 2026, alongside Google Search and Microsoft Bing in that category.
FOR PUBLISHERS Reddit says search referrals fell by more than 1 million a week on average in October; its letter does not say where those queries went.
FOR RIVAL ASSISTANTS TechCrunch described the obligations that apply above 45 million average monthly recipients, including opt-outs from profiling, data sharing with researchers and external audits.
The framework says: “Search gives way to assistants.”
OpenAI’s DSA page gives ChatGPT search about 185.6 million average monthly active recipients in the EU. The framework does not discuss these figures, and OpenAI does not use the framework’s terms.
OpenAI’s page gives only the latest six-month figure; the earlier figures come from TechCrunch, Reuters and Le Tribunal du Net’s reporting of OpenAI’s disclosures, and the March 2026 figure is reported as about 159 million. The metric does not show unique users, query volume or revenue, and none of the sources measures how much EU search activity moved to ChatGPT. The ratios and gains are our arithmetic.
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OpenAI puts ChatGPT search at about 185.6 million average monthly active recipients in the EU for the six months to 30 September 2026, about 4.1 times the DSA’s 45 million line by our arithmetic, with the gain over the prior disclosure at about 26.6 million, smaller than in the two periods before it.
A note on sourcing. The latest figure comes from OpenAI’s EU Digital Services Act help page, read on 29 October 2026; earlier figures come from TechCrunch, Reuters (via The Star) and Le Tribunal du Net’s reporting of OpenAI’s disclosures; Reddit’s quote comes from its Q3 2026 shareholder letter. The 4.1x ratio, the 54% and 17% rises and the period-on-period gains are our arithmetic.
Gennaro Cuofano is a CRO and tech executive who has worked in AI since late 2015, starting with bringing NLP, natural-language generation, voice and chatbot products to the marketing industry. His background is in law and finance: he holds a Master's degree in Law and an International MBA with an emphasis on corporate finance (LUISS Business School and the University of San Diego, 2012), and worked as a financial analyst at a real-estate investment firm in San Diego and as an assistant controller. His work focuses on business model strategy, business engineering and, more broadly, structural analysis: how companies make money, read from their own filings. He created FourWeekMBA and leads research there and at The Business Engineer, his newsletter on AI and business strategy, with over 95,000 subscribers and more than 1,000 published analyses. His writing has also appeared on Entrepreneur (for example, How to Digitize a Family Business in Europe) and HackerNoon. Find him on LinkedIn and Substack. See how we source.
