What the CMA has decided
The Competition and Markets Authority has formally designated Google as holding strategic market status (SMS) in general search services in the UK, a decision confirmed on 10 October 2025 after the regulator examined Google’s general search and search advertising activities. That designation, made under the UK’s new digital markets regime, gives the CMA powers to impose binding conduct requirements on how Google runs its search business.
Since then the CMA has moved to impose three separate conduct requirements. On 3 June 2026 it imposed a publisher conduct requirement, which it says is intended to secure a fairer deal for UK publishers and improve Google’s search services in this country. On 17 June 2026 it followed with fair ranking and data portability conduct requirements, again framed by the CMA as action to improve outcomes for UK businesses that rely on Google search traffic.
The unfinished piece: user choice
The fourth plank of the package, a user choice conduct requirement that would affect how ordinary searchers in the UK pick their default search engine, is not yet final. The CMA launched its first consultation on this and the other conduct requirements back on 28 January 2026, publishing full draft texts for data portability, publisher, fair ranking and user choice requirements alongside a round of stakeholder roundtables in February 2026 for businesses, trade bodies and civil society groups.
Rather than impose the user choice requirement alongside the other three, the CMA opened a further, more targeted consultation on 23 September 2026. Alongside the new consultation document, the regulator published user research specifically on how choice screens in search behave in practice, suggesting the design of any prompt shown to UK Google users is still being refined based on evidence of what actually works.
What it means for UK businesses and users
For publishers and businesses that depend on Google for traffic and advertising, the now-imposed publisher, fair ranking and data portability requirements are live obligations as of June 2026, covering how their content is ranked and how easily they can move or access their data. For everyday UK searchers, nothing has changed yet: the mechanism by which they might eventually be offered a genuine choice of search engine remains under consultation, with the CMA still testing choice-screen designs rather than mandating one.
Google has not issued a public response captured in the CMA’s case record beyond its earlier oral representations during the SMS designation process, summarised by the regulator in August 2025.
What to watch next
The key date to watch is the close and outcome of the September 2026 consultation on the user choice conduct requirement, which will determine when, and in what form, UK Google users start seeing choice screens for search engines. Businesses already subject to the publisher, fair ranking and data portability requirements should also watch for any CMA compliance updates, since those obligations are now in force rather than proposed.