Britain's Competition and Markets Authority today proposed the first conduct requirements under the Digital Markets, Competition and Consumers Act 2024, targeting Google's handling of publisher content in AI features and search result ranking transparency. The consultation launched January 28, 2026, marks the CMA's first use of powers to impose binding requirements on firms designated with Strategic Market Status following Google's September 30, 2025 designation for substantial market power in general search services.

Four conduct requirements form the core of the CMA's proposal: publisher controls over AI content usage, fair ranking demonstrations, choice screens on Android and Chrome, and data portability mechanisms. Publishers would gain ability to opt out of content usage in AI Overviews or AI model training outside Google Search, while Google must demonstrate to the CMA that ranking algorithms treat results fairly including in AI-powered features. The requirements respond to publisher complaints about traffic losses from AI features while maintaining Google's claimed £118 billion contribution to UK economic activity in 2023.

Publisher content controls address AI training concerns

The publisher conduct requirement enables content creators to prevent Google from using their material to power AI Overviews or train AI models outside search infrastructure. Google must implement practical attribution methods ensuring publisher content receives proper identification in AI-generated results. The requirement responds to concerns that Google extracts valuable publisher data without compensation while gaining competitive advantages in AI model development markets.

Owen Meredith, chief executive of the News Media Association, stated that "the CMA rightly recognises that Google is able to extract valuable data without reward, harming publishers and giving the company an unfair advantage over competitors in the AI model market, including British start-ups." The trade group representing UK news publishers characterized the measures as a "critical step" in bringing fair competition to digital economy operations.

Publishers participating in the CMA's consultation process expressed concerns about declining traffic from Google Search as AI Overviews provide direct answers within result pages. Google's Network advertising revenue declined 1% to $7.4 billion during second quarter 2025, while Search and other revenues reached $54.2 billion marking 12% growth, demonstrating divergence between platform-controlled advertising and publisher revenue streams.

The attribution requirements complement opt-out mechanisms by ensuring publishers receive identification when Google uses content in AI results even if they don't exercise full opt-out rights. Technical implementation details remain subject to consultation feedback, with the CMA seeking input on verification methods and enforcement mechanisms for attribution compliance.

Fair ranking requirement demands algorithmic transparency

Google must demonstrate that ranking algorithms apply objective, non-discriminatory criteria to both Google's own products and third-party content under the fair ranking conduct requirement. The CMA identified concerns that insufficient clarity exists around how Google's ranking systems and policies implement stated principles, particularly in AI Overviews and AI Mode features. Publishers reported inability to verify Google's application of ranking policies, creating perceptions about potential unfair up-ranking or down-ranking based on factors beyond relevance and quality.

The conduct requirement mandates that Google take decisions about its own products using the same criteria applied to equivalent third-party content, including relevance, quality, and user context considerations. Google must maintain an effective complaints process enabling businesses to raise concerns about unfair ranking treatment. The CMA acknowledged that balance must exist between addressing legitimate publisher concerns and avoiding undue burdens requiring algorithm modifications simply because publishers dispute ranking outcomes.

Sexual wellness providers including Lovehoney and Ann Summers submitted evidence to the CMA describing ranking challenges affecting their businesses. Multiple publishers expressed concerns during consultation processes about ranking changes implemented with limited transparency regarding timing or justification for modifications.

The requirement extends to AI-powered search features where Google's query fan-out technique processes hundreds of related searches simultaneously when users pose questions in AI Mode. Google expanded AI Mode to all United States users May 20, 2025, fundamentally changing how content creators must approach search optimization by synthesizing information from multiple sources rather than ranking individual pages.

Google's ranking infrastructure increasingly incorporates large language models as fundamental components rather than add-on features, according to Department of Justice court documents from ongoing antitrust litigation. RankEmbed technology embeds both query and document into embedding space considering semantic properties alongside traditional signals, while performing poorly for tail queries representing less common search patterns.

Choice screens target default search dominance

The CMA proposes making default choice screens legal requirements on Android mobile devices while introducing equivalent mechanisms on Chrome browser. The requirement addresses Google's control over search access points through default agreements with device manufacturers and browser vendors. Google accounts for more than 90% of all general search queries in the UK, maintaining dominant position without rivals gaining ground over 15 years according to the CMA's designation findings.

Choice screens enable users to select alternative search engines during device setup or browser installation rather than accepting Google as pre-configured default option. The European Union's Digital Markets Act previously mandated similar requirements for designated gatekeepers, with the CMA's proposal building on implementation experiences from those parallel efforts.

The requirement responds to barriers preventing competitor search engines from gaining distribution despite potential quality advantages. Google's vast index, data ecosystem, and distribution agreements create formidable obstacles for rival services attempting to reach users at scale. Consumer switching costs remain high even when alternative options exist, with default configurations exerting powerful influence over actual usage patterns.

Rocio Concha, director of policy and advocacy at Which?, stated that "these proposed requirements are needed to make sure businesses and consumers get a fair deal from Google. Wider availability of better choice screens are a necessary first step to opening up the market for other search tools."

Implementation details subject to consultation include screen design specifications, frequency of presentation to users, and mechanisms ensuring meaningful choice rather than dark pattern manipulation. The CMA must balance facilitation of genuine competition with user experience considerations avoiding excessive friction in device setup or browser installation processes.

Data portability requirements enable service switching

Google must implement data portability mechanisms enabling individuals and businesses to obtain and reuse search data across different services under the fourth conduct requirement. The measure builds on General Data Protection Regulation mandates while addressing shortcomings that rendered GDPR data portability ineffective in practice. The CMA explicitly stated the measure would build on similar requirements imposed under the Digital Markets Act in the European Union, extending EU-developed portability tools to UK users.

Data portability enables users to transfer search history, preferences, and related information to competing search services, reducing switching costs that currently lock users into Google's ecosystem. The requirement addresses concerns that Google's accumulated user data creates network effects reinforcing market position even when alternative services offer competitive features.

Technical implementation challenges include standardizing data formats enabling interoperability across different search platforms, establishing security protocols protecting user information during transfer processes, and defining scope of data subject to portability requirements. The CMA seeks consultation feedback on appropriate balance between comprehensive data access and practical implementation constraints.

Publishers and advertisers participating in Google search advertising collectively spent more than £10 billion during 2024, with approximately 200,000 to 300,000 unique entities using Google's search advertising in the UK according to CMA documents. Search advertising spending nearly doubled from £8 billion in 2019 to £15 billion in 2023, while Google maintained dominant market position throughout the growth period.

The data portability requirement complements other conduct requirements by enabling users to switch services after evaluating alternatives through choice screens, while ensuring businesses can migrate to competing platforms without losing accumulated search optimization data. Implementation timelines remain subject to consultation with stakeholders including consumer groups, competing search providers, and technical standards organizations.

Consultation process establishes implementation timeline

The CMA established February 25, 2026, as the deadline for stakeholder feedback on proposed conduct requirements. A final decision will follow consideration of submissions received during the consultation period. Sarah Cardell, Chief Executive of the CMA, stated that "today is an important milestone as we consult on the first conduct requirements under the digital markets competition regime in the UK. These targeted and proportionate actions would give UK businesses and consumers more choice and control over how they interact with Google's search services."

The measures represent Category 1 priorities anticipated to deliver immediate benefits for businesses and consumers, contrasting with Category 2 measures requiring further consideration before implementation starting first half of 2026. Category 2 interventions include fair treatment of competing specialized search services, fair and reasonable use of publisher content with potential payment terms, and greater transparency in search advertising auctions.

Category 3 measures covering longer timeframes from 2027 include consumer control over data usage, restrictions on Google's ability to share data within its ecosystem, and measures addressing ad load, auctions, and advertising prices. The categorization enables phased implementation addressing priority concerns while developing more complex interventions requiring extended analysis and stakeholder engagement.

The consultation coincides with parallel enforcement actions in other jurisdictions. The European Commission imposed a €2.95 billion fine on Google September 5, 2025, for abusing dominant positions in publisher ad server and programmatic ad buying markets, while evaluating behavioral remedies Google submitted in November 2025. The U.S. Department of Justice seeks structural remedies including AdX divestiture in parallel antitrust proceedings, with closing arguments conducted November 17, 2025.

Google's response to the proposed conduct requirements remains pending as the consultation period proceeds. The company previously warned that UK rules could slow innovation following October 2025 designation, emphasizing that UK businesses and consumers had been among first to benefit from Google innovations often months before European counterparts. Oliver Bethell, Senior Director of Competition at Google, stated the company "supports the CMA's goal to ensure the UK's competition framework mirrors the best interests of UK consumers and businesses."

Publishing industry faces AI traffic challenges

The conduct requirements address publisher concerns about declining traffic as AI features retain users within Google's search interface rather than directing visits to external websites where advertising generates revenue. Traffic patterns demonstrate AI impact through multiple data points. Chartbeat data showed Search referrals declining from approximately 16% to 10% of total publisher traffic during periods when AI Overviews rolled out to more than 100 countries, with inflection points occurring in late October 2024 coinciding with international market expansions.

Major publishing organizations documented financial consequences from AI search integration. BuzzFeed filed warnings with securities regulators August 2025 identifying five specific risks from AI search integration including reduced referral traffic, diminished advertising revenue, increased platform control over content visibility, and challenges regarding AI crawler access decisions. Dotdash Meredith reported that AI Overviews appear on roughly one-third of search results related to the company's content, with publishers seeing slight performance declines on affected pages.

Research from Ahrefs published April 2025 found that when AI Overviews appear in search results, the first organic link loses an average of 34.5% of clicks. Advertising technology platform Teads reported during November 6, 2025 earnings call that pageview declines of 10-15% occurred during third quarter 2025, marking one of the first times a major advertising technology platform quantified traffic impact publishers face from AI-powered search features.

Premium ad networks responded to traffic volatility by adjusting publisher qualification standards. Raptive reduced pageview requirements from 100,000 to 25,000 monthly visits October 16, 2025, marking 75% reduction from long-standing thresholds. Mediavine moved toward revenue-centric model requiring sites to demonstrate at least $5,000 in annual ad earnings, shifting focus from traffic volume to engagement quality amid algorithmic volatility documented in Google's December 2025 core update.

The publisher conduct requirement attempts to address these challenges by providing opt-out mechanisms and attribution requirements, though implementation timelines extend beyond immediate traffic concerns. Publishers seeking alternatives to Google search dependence have explored direct audience relationships through newsletter subscriptions, social media followings, and app downloads as intermediated search traffic becomes less reliable for sustainable business models.

Timeline

Summary

Who: The UK Competition and Markets Authority proposed conduct requirements for Google following Strategic Market Status designation in September 2025. Publishers including the News Media Association, consumer advocacy group Which?, and affected businesses participated in consultation processes informing the proposed measures.

What: Four conduct requirements address publisher content controls in AI features, fair ranking demonstrations in search results, choice screens on Android and Chrome, and data portability mechanisms. Publishers gain opt-out rights for AI training and attribution requirements, while Google must prove ranking fairness including in AI Overviews and AI Mode.

When: The CMA launched consultation January 28, 2026, with feedback deadline February 25, 2026. Final decisions follow stakeholder submission review, with Category 1 measures implementing ahead of Category 2 interventions starting first half of 2026 and Category 3 measures from 2027.

Where: The conduct requirements apply to Google's operations in the United Kingdom, affecting more than 90% of UK general search queries and over £10 billion in annual search advertising spending. The measures complement parallel enforcement in the European Union and United States targeting Google's market power in search and advertising technology.

Why: The CMA determined Google's substantial and entrenched market power creates barriers preventing fair competition in search services. Publishers documented traffic declines from AI features reducing website visits, while lack of transparency in ranking algorithms and limited user choice in default search engines justified intervention under digital markets legislation aimed at promoting innovation and consumer welfare.

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