Key takeaways
- OpenAI Ireland Limited says ChatGPT search averaged approximately 185.6 million monthly active recipients in the EU in the six months ending Sept. 30, 2026. It publishes the figure under Article 24(2) of the Digital Services Act (DSA) [1].
- The figure OpenAI published for the previous six months, ending March 31, 2026, was approximately 159.1 million, according to an archived copy of the same page [2]. OpenAI does not say whether it counted the same way in both periods.
- OpenAI says the average was “calculated solely for the purposes of complying with our DSA obligations and should not be relied upon or used for other purposes” [1]. It counts recipients of ChatGPT’s search features, not searches.
Direct answer: OpenAI’s new DSA disclosure puts ChatGPT search at about 185.6 million average monthly active recipients in the EU for the six months ending Sept. 30, 2026. It is a regulatory metric, not a count of all ChatGPT users or of search volume.
What happened: OpenAI updated its help page on the EU Digital Services Act on Oct. 29, 2026 (UTC), according to the page’s “Updated” label when we opened it on Oct. 30 [1]. In a section on monthly active recipients, it says OpenAI Ireland Limited publishes the average “monthly active recipients” of “ChatGPT search (i.e. our online search features) in the European Union, calculated over a six-month period,” in accordance with Article 24(2) of the DSA [1]. The new figure replaces the one for the six months ending March 31, 2026, which an archived copy of the page from Oct. 6, 2026, shows as approximately 159.1 million [2].
What does the figure measure?
- Who reports it. OpenAI Ireland Limited, which the European Commission lists as the provider’s main establishment in the EU [1][4].
- What it covers. ChatGPT search, which OpenAI defines on the page as “our online search features,” in the EU [1].
- How it is averaged. An average of monthly active recipients over six months [1]. The page does not describe how OpenAI counts a recipient.
- What it is for. DSA compliance only. OpenAI says it “should not be relied upon or used for other purposes” [1].
Why does OpenAI publish it?
On Aug. 31, 2026, the European Commission designated ChatGPT a very large online search engine (VLOSE) under the DSA, and designated Reddit and Roblox as very large online platforms [3]. The Commission said these services “declared that they reach at least 45 million average monthly users in the EU and thus meet the threshold for designation,” and that they have four months after notification to comply with additional obligations, such as assessing and mitigating systemic risks [3]. The Commission’s French-language announcement describes ChatGPT as a hybrid service that falls in the DSA’s online search engine category [5].
The Commission’s list of designated services, updated Oct. 28, 2026, still showed 159.1 million for ChatGPT [4]. It shows 364 million for Google Search and 119 million for Bing, and says the figures are as reported by the providers and “without prejudice to the assessment by the Commission of the methodology used to calculate the active recipients of service” [4]. The list does not give a reporting period for each figure, so we do not compare them directly with the new ChatGPT number.
Why it matters
Our view: For brands planning for AI search in Europe, this is a legally required usage figure for an AI search product, and OpenAI has now published it for two consecutive six-month periods. It reports average monthly active recipients of ChatGPT’s search features, not how often ChatGPT cited or sent visitors to any website. As with OpenAI’s search indexing pilot with Cloudflare, audience figures and citations are separate measures.
What we don’t know yet
- How OpenAI counts a monthly active recipient of ChatGPT search. The page does not say.
- Whether OpenAI counted the same way in both periods.
- How the EU figure splits by country. The page gives an EU total only.
- How many of these recipients clicked through to websites. OpenAI publishes no referral figures on the page.
- Whether the Commission accepts OpenAI’s methodology. Its list says the figures are without prejudice to its assessment [4].
What to do now
- If you cite the number, use OpenAI’s terms: approximately 185.6 million average monthly active recipients of ChatGPT search in the EU, six months ending Sept. 30, 2026, published for DSA compliance. Do not present it as ChatGPT users or search volume.
- Do not use it as a traffic estimate. Measure visits and conversions from ChatGPT in your own analytics.
- Check that OpenAI’s search crawler can reach your pages; our report on the Cloudflare pilot covers OpenAI’s crawler settings.
Disclosure: AVJ pays OpenAI standard prices for a ChatGPT Pro subscription and for API access, receives no credits or special terms, and uses OpenAI models among its editorial tools (see our AI use policy). The AVJ Citation Index will also measure answers from OpenAI’s API. AVJ has no other commercial relationship with OpenAI.
Update log: Oct. 30, 2026 — First published.
Sources
[1] OpenAI. “EU Digital Services Act (DSA).” OpenAI Help Center. Updated Oct. 29, 2026 (per the page’s relative “Updated” label). Accessed Oct. 30, 2026. https://help.openai.com/en/articles/8959649-eu-digital-services-act-dsa
[2] OpenAI. “EU Digital Services Act (DSA).” OpenAI Help Center. Archived copy captured Oct. 6, 2026, Internet Archive Wayback Machine. Accessed Oct. 30, 2026. https://web.archive.org/web/20261006074704/https://help.openai.com/en/articles/8959649-eu-digital-services-act-dsa
[3] European Commission. (2026, Aug. 31). “Commission designates ChatGPT, Reddit, Roblox under Digital Services Act.” Press release, Shaping Europe’s digital future. Accessed Oct. 30, 2026. https://digital-strategy.ec.europa.eu/en/news/commission-designates-chatgpt-reddit-roblox-under-digital-services-act
[4] European Commission. “Supervision of the designated very large online platforms and search engines under DSA.” Shaping Europe’s digital future. Information updated Oct. 28, 2026. Accessed Oct. 30, 2026. https://digital-strategy.ec.europa.eu/en/policies/list-designated-vlops-and-vloses
[5] European Commission, Representation in France. (2026, Aug. 31). “DSA : la Commission notifie leur désignation à ChatGPT, Reddit et Roblox.” In French. Accessed Oct. 30, 2026. https://france.representation.ec.europa.eu/informations-et-evenements/informations/dsa-la-commission-notifie-leur-designation-chatgpt-reddit-et-roblox-2026-08-31_fr
How this was made
Prepared with AI assistance from the sources cited above. Editorial review by Nhi Phan (editor) and fact-checking by Jackies continue after publication; any change will be recorded in the update log and in our Corrections Policy and Log.