CMA imposes two new conduct requirements on Google under

Cresthaven Analytics Intelligence Brief

Headline

CMA imposes two new conduct requirements on Google under the digital markets regime covering search rankings and data portability

Executive Summary

The UK Competition and Markets Authority issued two new conduct requirements against Google on June 17, 2026, under the strategic market status regime. The requirements address fairness in search rankings, including AI Overviews, and user data-sharing rights.

Bottom Line

The CMA's two conduct requirements place binding fairness and data-portability obligations on Google's UK search operations under the strategic market status regime. Businesses reliant on Google search rankings now have a formal regulatory standard against which to assess and, where appropriate, challenge ranking treatment. The requirements also establish the first operational precedent for how the CMA exercises conduct powers under the 2024 digital markets statute, with further SMS designations in progress.

Key Regulatory Signals

Search Ranking Fairness Now a Binding Obligation: Google must ensure its search ranking algorithms, including the AI Overviews feature, treat third-party content and businesses on fair and non-discriminatory terms. Businesses that depend on organic search visibility for customer acquisition face a changed enforcement baseline if Google's ranking practices are challenged.
Data Portability Requirement Activated: Google must enable users to share their search and activity data with third parties under the new conduct requirement. Platforms and services seeking to compete with Google on personalisation or recommendation quality gain a formal data-access pathway under UK law.
Strategic Market Status Regime Produces Its First Substantive Conduct Orders: These requirements represent the first binding conduct interventions issued under the Digital Markets, Competition and Consumers Act 2024 following Google's strategic market status designation. The regime is now operational at the enforcement level, not merely the designation stage.
Compliance Obligations Land on Google Immediately: Conduct requirements under the strategic market status regime take effect upon issuance. Google's UK legal and product teams carry an immediate obligation to assess ranking systems and data infrastructure against the new requirements, with CMA oversight active from the date of publication.
Precedent for Further SMS Designations: The CMA has active strategic market status investigations into other large digital firms. The issuance of conduct requirements against Google establishes the operational template for how the regime will function when further designations conclude.

Regulatory Delta

- No direct precedent exists for binding conduct requirements of this kind in UK digital markets. This is the first enforcement action under the strategic market status regime created by the Digital Markets, Competition and Consumers Act 2024.

- The requirements move the regime from designation into active conduct supervision, extending CMA authority over algorithmic product decisions including AI-generated search features.

- The EU Digital Markets Act designates Google as a gatekeeper under comparable provisions and provides a parallel international framework. The CMA's action reflects a convergent but independently grounded regulatory posture.

Materiality Classification

HIGH — The CMA has issued the first binding conduct requirements under the Digital Markets, Competition and Consumers Act 2024, creating immediate compliance obligations for Google and establishing an operational precedent that applies to all forthcoming strategic market status designations across the digital sector.

Intelligence Outlook

Monitor the CMA for compliance reporting timelines, any interim enforcement steps, and the conclusion of active strategic market status investigations into other designated digital firms.