UK Imposes First Conduct Requirements on Google Under New Digital Markets Regime, Targeting AI Overviews and Search Dominance
The CMA proposed its first conduct requirements under the UK's new digital markets law, targeting Google's AI Overviews, search ranking, and choice screens, while securing app store commitments from Apple and Google effective April 1.
Overview
The United Kingdom’s Competition and Markets Authority has proposed four conduct requirements for Google’s search services — the first ever issued under the Digital Markets, Competition and Consumers Act 2024 — that would force the company to give publishers meaningful controls over how their content is used in AI-generated search features, expand choice screens across Android and Chrome, guarantee at least 30 business days’ notice before material ranking changes, and formalize data portability for UK users. Separately, the CMA secured commitments from both Apple and Google to reform their app store review processes and enhance iOS interoperability, with those obligations taking effect on April 1, 2026.
The actions mark the first concrete enforcement under a regulatory regime that Parliament designed to move faster than traditional antitrust litigation, and they arrive as regulators on both sides of the Atlantic intensify scrutiny of how dominant platforms use publisher content to power generative AI features.
The Four Conduct Requirements for Google Search
Google was designated as having “strategic market status” in general search and search advertising on October 10, 2025, after the CMA found the company holds more than 90 percent of UK general search queries and receives over 10 billion pounds annually in search advertising from more than 200,000 UK businesses. That designation triggered the CMA’s authority to impose tailored conduct requirements under the DMCCA’s framework of “fair dealing, open choices, and trust and transparency,” according to the CMA’s consultation documents.
The four proposed requirements, published on January 28, 2026, address distinct areas of concern:
Publisher Content Controls
The most consequential requirement targets the intersection of search and generative AI. Currently, Google’s crawler simultaneously indexes websites for search results and collects content for AI Overviews — the AI-generated summaries that appear above traditional search results. Publishers who block the crawler lose visibility in search entirely. The proposed requirement would compel Google to provide effective controls allowing publishers to withhold their content from generative AI training and grounding without suffering search ranking penalties. Google would also be required to publish clear documentation on how publisher content is used and ensure reasonable attribution when content appears in AI-generated features.
The CMA considered but rejected requiring Google to operate separate crawlers for search indexing and AI content collection, estimating annual costs of 25 to 50 million pounds and concluding that improved content controls would be more proportionate.
Fair Ranking
Google would be required to provide at least 30 business days’ advance notice before implementing material changes to its search ranking algorithms — a measure aimed at reducing the operational disruption that sudden ranking shifts inflict on publishers and businesses that depend on organic search traffic. The requirement also mandates a clear complaints process for affected publishers and an alternative dispute settlement mechanism for businesses manually excluded from Google’s search index. The CMA estimated this requirement’s costs to Google at under 15 million pounds over five years, against search services worth 80 to 160 billion pounds annually.
User Choice
The proposed requirement would expand mandatory search engine choice screens across Android devices and Chrome browsers, addressing what the CMA identified as coverage gaps affecting 15 to 35 million devices annually. Only about 20 percent of Android devices currently display choice screens. The CMA also proposed a test-drive functionality — a suggested 14-day trial period before users confirm their search provider selection — and a device-level default setting that would allow users to select one search provider across multiple access points. The CMA estimated the benefits would exceed costs if just 30,000 to 50,000 additional annual switches occurred, representing less than 0.5 percent of additional choice screen showings.
Data Portability
The lightest-touch measure would formalize Google’s existing DMA-compliant data portability API for UK users on terms identical to those available in the European Economic Area. While Google already provides this capability voluntarily, the CMA argued that a formal requirement removes investment uncertainty for startups building on Google’s search data and signals regulatory convergence with EU standards.
App Store Commitments From Apple and Google
In a parallel action, the CMA secured commitments from Apple and Google following both companies’ designation with strategic market status in mobile platforms on October 22, 2025. The commitments, scheduled to take effect on April 1, 2026, require both companies to review apps in a fair, objective, and transparent manner without discriminating against competing apps or favoring their own. App ranking must also be conducted without preferential treatment.
Apple additionally committed to considering interoperability requests from developers fairly and objectively, enabling third-party apps to better access features and functionality within iOS — including capabilities related to digital wallets and live translation. Both companies will be required to submit regular monitoring reports to the CMA covering app submission rates, approval and rejection rates, review timeframes, complaints received, and interoperability request outcomes.
The CMA noted that the commitments do not address commission charges — which range up to 30 percent and were identified in July 2025 as a “key concern” — leaving that issue for potential future action.
A Distinctive Regulatory Approach
The UK’s framework differs from the EU’s Digital Markets Act in several significant respects. Where the DMA imposes uniform obligations on all designated gatekeepers, the DMCCA requires the CMA to conduct evidence-based proportionality assessments with quantified cost-benefit analyses for each proposed requirement. The CMA published detailed economic impact assessments alongside all four Google search proposals, including estimated compliance costs and market-wide benefits.
The approach also differs in pace. The DMA took effect in March 2024, and the European Commission has already opened multiple formal investigations, including a probe launched in December 2025 examining whether Google’s AI Overviews and AI Mode violate EU competition laws by using publisher content without appropriate compensation. The UK’s DMCCA entered force on January 1, 2025, and the CMA completed its first designations within ten months — but the conduct requirements remain in consultation, with a final decision still pending after the February 25 consultation deadline closed.
Sarah Cardell, CMA Chief Executive, stated that the proposed measures represent “targeted and proportionate actions” that “would give UK businesses and consumers more choice and control over how they interact with Google’s search services,” according to the CMA press release.
What Comes Next
The CMA is currently analyzing responses from the public consultation, which closed on February 25, 2026, and is expected to issue a final decision in the coming weeks. If adopted, the conduct requirements would carry a six-month implementation period with monthly progress reporting from Google.
The regulator has signaled that the initial package is only the beginning. A second category of longer-term measures — potentially addressing Google’s self-preferencing in specialized search services, the placement of Gemini AI relative to competitors, advertiser control over ad auctions, and search result display transparency — could follow later in 2026.
Failure to comply with conduct requirements under the DMCCA can result in fines of up to 10 percent of a firm’s global turnover, making the regime one of the most heavily penalized digital markets frameworks in the world alongside the EU’s DMA. The CMA also retains the authority to escalate from conduct requirements to pro-competitive interventions — more intrusive structural measures that could in theory extend to business divestiture.