UK CMA Competition Brief

Headline

CMA introduces two binding conduct requirements on Google search ranking and data portability under UK digital markets regime

Executive Summary

The Competition and Markets Authority (CMA) introduced two conduct requirements for Google's general search services on June 17, 2026, under the UK digital markets competition regime. The first requires fair and transparent organic search ranking. The second places Google's existing voluntary data portability tool on a formal legal footing.

Bottom Line

The CMA's two conduct requirements place binding obligations on Google covering organic search ranking fairness, including AI-generated search surfaces, and user search data portability within the UK. Google faces a three-month implementation deadline for data portability and a six-month deadline for fair ranking, with CMA compliance monitoring through regular reporting and ongoing stakeholder engagement. Cresthaven reading: businesses that distribute products or services through Google Search in the UK, and third-party firms seeking to build on Google search data, now operate under a legal framework with defined ranking standards and a structured data access mechanism rather than voluntary arrangements.

Key Regulatory Signals

• Fair Ranking Now a Legal Obligation for Google: Under the first conduct requirement, Google must rank organic search results, including those surfaced in AI Overviews, using objective and non-discriminatory criteria. Google must also provide advance notice of significant ranking changes and introduce formal processes for businesses to raise and resolve ranking concerns. Google has six months to implement this requirement.
• Data Portability Moves from Voluntary to Legally Binding: The second conduct requirement places Google's existing UK Data Portability Application Programming Interface on a legal footing. Third-party firms, such as rewards platforms and personalized recommendation services, gain the certainty needed to invest in products built on user search data. Google has three months to implement this requirement.
• AI Search Features Explicitly Within Scope: The fair ranking requirement covers AI Overviews and is framed to apply as search continues to evolve through AI-based features including AI Mode. The CMA states it may introduce further measures if the requirements prove insufficient given the pace of change in search.
• Parity with EU Digital Markets Act Rights: The CMA states that UK user data portability rights under the new requirement are now on a par with those established for EU users under the EU's Digital Markets Act. Cresthaven reading: businesses building data-driven products for UK consumers face a comparable legal access framework to that available in the EU, reducing the structural gap that previously existed between the two regimes.
• Further CMA Activity Signaled for Summer 2026: The CMA states that more activity is expected over the summer, following earlier June actions giving publishers control over content use in Google's AI features and a fourth strategic market status investigation launched into Microsoft's business software ecosystem.

Regulatory Delta

• The fair ranking requirement explicitly covers AI Overviews. This marks a structural departure, extending search-ranking fairness obligations into generative AI-powered search surfaces for the first time under this regime.
• The EU Digital Markets Act established the international reference point for search data portability obligations. The CMA's action explicitly aligns UK user rights with that standard, signaling convergence between the two regimes on this mechanism.

Materiality Classification

HIGH — The CMA has introduced binding conduct requirements with defined implementation deadlines under the UK digital markets competition regime, imposing new legal obligations on Google's search ranking and data portability practices that directly affect businesses distributing through Google Search and third-party firms building on search data across the UK market.

Intelligence Outlook

Monitor the CMA's Google Search page for further conduct requirements and compliance reporting expected over summer 2026, and for any additional measures the CMA states it may introduce if current requirements prove insufficient.