US company OpenAI has shared its new user numbers on Tuesday 21 October 2025. As the AI bot ChatGPT hits 120 million EU users, it could soon be subjects to the EU’s Digital Services Act, the strictest set of rules for online platforms.
According to the DSA, platforms with over 45 million monthly users are faced with a number of strict rules in order combat the spread of illegal content and products online. This is explained through their significant societal impact, improving their potential to spread harmful content and disinformation.
At the moment, 25 platforms including X, Amazon, TikTok, Shein, Facebook, and Instagram are subject tot the Digital Services Act (DSA). This requires them to be more transparent in their reporting and to pay higher supervisory fees, thus paying the European Commission to keep an eye on their activities and to intervene when needed. Several investigations regarding possible DSA breaches have already been launched but so far, none have been closed.
"For the six-month period ending 30 September 2025, ChatGPT search had in combination approximately 120.4 million average monthly active recipients in the European Union" (compared to 41.3 million for the six-month period ending 31 March 2025) pic.twitter.com/sopP52dnYZ
— Tibor Blaho (@btibor91) October 21, 2025
New users, new rules
For the purpose of complying with the DSA obligations, OpenAI has calculated its average number of monthly users. According to the data, for the six-month period ending 30 September 2025, ChatGPT search had approximately 120.4 million average monthly active recipients in the European Union.
“In accordance with our obligations under Article 24(2) of the DSA, OpenAI Ireland Limited publishes information on the average ‘monthly active recipients’ of ChatGPT search (i.e. our online search features) in the European Union, calculated over a six-month period”, said OpenAI.
According to a spokesperson from the European Commission on Wednesday 22 October, the Commission is aware of ChatGPT’s new user numbers and is currently assessing the information.
1 year of a safer digital space for EU users!
— European Commission (@EU_Commission) February 18, 2025
It has been a game-changer in monitoring e-platforms.
How did the DSA’s first year benefit you:
👨🏽💻 More online rights and transparency online
🗳️ Actions to safeguard the integrity of elections
✋🏽 Clarity on why you see certain ads pic.twitter.com/juLyTZOckM
“It could potentially be in the scope of the DSA, an analysis has to be done on a case by case basis”, the spokesperson said.
According to the European Commission, in order to determine if ChatGpT will be subject to the DSA it is necessary to define whether or not the generative AI technology is integrated into a type of service or platform that can be designated.
For everyone, it ensures that AI systems are developed according to our principles, delivering trustworthy, human-centric AI built on stringent European ethical and regulatory standards.
— European Commission (@EU_Commission) October 22, 2025
The first 19 platforms subject to the Digital Services Act were appointed back in 2023. Since then, their number has grown to 25 and might soon hit 26. Contrary to smaller platforms, oversight is organised by the European Commission directly and not by the national authorities of the member state in which the companies’ EU headquarters are based.
On 21 October 2025, OpenAI also officially launched a new web browser, ChatGPT Atlas. With ChatGPT built into its system, the browser will support past conversations to assist users and users will also be able to put in a request to “summarize content, compare products, or analyze data from any site” through the sidebar.
