Search and Search Advertising are critical for UK consumers and businesses so it’s vital that effective competition delivers good outcomes.
Overview
Google search accounts for more than 90% of all general search queries in the UK, with millions of people relying on it as a key gateway to the internet. It is also a critical route for UK businesses to reach customers - over 200,000 firms in the UK collectively spent more than £10 billion on Google search advertising last year.
The new Digital Markets Competition Regime that came into force in January 2025 empowers the CMA to take targeted and proportionate action to improve competition in critical digital markets.
As a first step, today we’re consulting on our proposed decision to designate Google with ‘strategic market status’ (‘SMS’) in search under the regime. Alongside this, we’ve set out the potential actions we would take to strengthen competition and deliver better outcomes – enabling more choice and control for consumers, and lower costs for businesses – should we decide to designate Google. These measures could help to unlock broader growth, investment and innovation in the UK tech sector and beyond. Specifically, today we are publishing a roadmap of how we would propose to prioritise these actions during the first half of any designation period.
We will issue a final designation decision in October. Should Google be designated, we would expect to consult on a first set of interventions shortly afterwards.
What we have heard through our investigation so far
Through our investigation thus far, we’ve heard widespread concerns, including:
- Google’s index of billions of websites, its access to trillions of historical searches, and its ecosystem of information, are extremely hard for others to replicate.
- Competition in search advertising is not working as effectively as it should. The amount spent by UK business entities for search advertising on Google last year was equivalent to more than £33,000 per advertiser. If competition was working well, we would expect these costs to be lower.
- Google may not consistently provide fair search ranking and is able to rapidly (and with limited transparency over when or why) introduce changes to ranking and presentation of results which affect businesses’ ability to reach customers.
- Google’s bargaining position can impact fair and reasonable terms for publishers, including fair payment terms for the use of their content. Insufficient controls about how their content is used in Google Search (including AI Overviews) also limits news publishers’ ability to monetise their content.
- Google’s deals with companies like Apple and Samsung to be the default search engine on their devices can make it more difficult for competitors to reach customers.
- Innovative businesses struggle to compete as people can't easily share their search data with firms developing innovative new services which could benefit them.
These issues may harm UK businesses through higher costs and reduced innovation, as well as UK consumers through less choice and control.
What this means under the Digital Markets Competition Regime
The new regime can help unlock opportunities for innovation and growth, by promoting competition in digital markets while protecting UK consumers and businesses from unfair or harmful practices.
It is built on a principle of proportionality, applying to firms with a sufficiently powerful position – or ‘strategic market status’ (‘SMS’) – in particular digital activities in the UK.
We have provisionally found that Google has met the legal tests required to designate it with SMS in relation to its general search and search advertising activities. These tests relate to:
1. Substantial and entrenched market power
2. A position of strategic significance
We are now consulting on this provisional designation. If confirmed, the CMA would be able to introduce measures to address specific aspects of how Google operates these activities in the UK.
Roadmap of possible measures to improve competition in search
The UK regime is uniquely designed to be flexible and highly targeted, with a participative engagement process – involving all stakeholders, from the largest firms to challengers and consumer groups. The CMA is also embedding our ‘4Ps’ - Proportionality, Pace, Predictability and Process into our approach, to avoid any action we take hampering innovation or creating uncertainty which could chill investment.
To support pace and predictability, alongside our SMS investigation we’re looking in parallel at potential actions we might take were Google to be designated. Specifically, to provide greater predictability for Google and other market participants, we’re going further than the legislation requires by publishing a Roadmap of how we propose to prioritise these actions during the first half of any designation period.
The measures in the roadmap have two objectives. First, to ensure consumers and businesses are treated fairly and can have confidence in the way they interact with Google in search. Second, to promote competition and innovation through targeted actions, such as ensuring that all firms (including Google) can compete and innovate in new AI-based search interfaces.
We have laid out a phased approach for any action we may take.
Category 1 measures
Category 1 measures include early priorities which we would expect to deliver some of the quickest benefits for UK businesses and consumers. These focus on greater choice and control, including through:
- choice screens: ensuring people can easily choose and switch between search services (potentially including AI Assistants), by making default choice screens a legal requirement
- fair ranking principles: ensuring Google’s ranking and presentation of search results is fair and non-discriminatory, with an effective process for raising and investigating issues
- publisher controls: ensuring transparency, attribution and choice for publishers in how their content, collected for Search, is used in Google's AI services (including AI Overviews and Gemini AI Assistant)
- data portability: helping innovative new businesses to bring products and services to market by ensuring people can transfer their data (such as search history)
Category 2 measures
Category 2 includes a set of more complex issues where we think there may be a case for action, but which require further consideration, and potential interventions may be more complex to develop. These include:
- publisher concerns about the impact of Google’s bargaining position and whether they are receiving fair and reasonable terms
- concerns about Google’s treatment of rival specialised search firms
- concerns about transparency and control in relation to search advertising
We’ve also taken the opportunity to indicate areas that we have deprioritised (Category 3).
Wider international context
The UK is a one of a number of jurisdictions around the world taking action to support businesses and consumers through open and innovative digital markets.
We have identified a further set of possible actions (for example, restricting use of default agreements and providing access to underlying search data) which are currently the subject of live litigation between the US Department of Justice and Google.
We will consider our approach in these areas in light of developments over the coming months. This is in line with the CMA’s prioritisation principles and the government’s recent strategic steer, which encourages the CMA to consider where we are best placed to act.
We will update on our approach to these issues in early 2026.
How we are taking account of Generative AI
We have carefully considered how generative AI could affect Google’s position in search.
Search is changing, with use of AI assistants growing but still dwarfed by that of Google search. Google is also well-positioned to respond to competitive threats from AI assistants and is now continuously incorporating generative AI features (such as AI Overviews) into existing search products, as well as developing its own AI assistant - Gemini.
Reflecting this evolving landscape, the scope of our proposed SMS designation for search would include Google’s AI Overviews and other Generative AI search features. Based on how it is currently offered and used, we have provisionally decided that Gemini AI assistant should not be included as a product within this scope. We recognise the need for certainty, both for Google and for third parties. We will keep this under careful review – as provided for in the legislation – as usage of Gemini develops.
What next?
We will be consulting on the proposed SMS designation over the next month, ahead of a final decision deadline of 13 October.
We welcome views from all parties on our accompanying Roadmap.
We expect to consult on a first set of Category 1 actions shortly after any designation decision. We will publish an updated roadmap addressing our approach to the more complex issues we have identified in early 2026.
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