CMA Launches Consultation on Steering Conduct Requirement for Google's Mobile Platform Under UK Digital Markets Regime
In June 2026, the Competition and Markets Authority (CMA) launched a consultation on a proposed steering conduct requirement directed at Google in connection with its mobile platform. The consultation, opened on 30 June 2026, forms part of the CMA's ongoing programme of work under the UK's digital markets competition regime, following the CMA's final decision in October 2025 to designate Google as having strategic market status (SMS), a classification introduced by the UK's digital markets framework that applies to companies with substantial, entrenched market power in a designated digital activity. Google's SMS designation covers its mobile operating systems, native app distribution, and mobile browser and browser engine. The steering conduct requirement being consulted on would allow app developers to steer their own users to alternatives outside Google Play, including completing transactions elsewhere, and would require any fee Google charges for that steering to be justified against cost and value. A separate call for evidence on recent developments in Apple's and Google's app store rules was published on 1 April 2026, and on the same date the CMA published final commitments given by Google on app certainty grounds, covering app review, app ranking, and use of data. Apple received its own SMS designation and is subject to a parallel proposed steering conduct requirement consultation. The CMA's programme of work represents the first live application of the UK's digital markets conduct requirements to major platform operators, establishing how those requirements will be enforced in practice.
Why this matters
The UK's digital markets competition regime, which introduced the SMS designation framework, is now moving from investigation into active conduct regulation, with Google as one of its first major subjects. The steering conduct requirement is commercially significant because it would let app developers point their users to cheaper payment options outside Google Play and would cap what Google can charge for that steering, striking directly at the app store commission that sits at the centre of Google's mobile revenue model. This is the first time a UK regulator has sought to impose bespoke real-time behavioural requirements on a designated platform of this scale, and the CMA's approach will be closely watched by the European Commission and other regulators assessing similar regimes. The parallel process running against Apple means two of the world's largest technology companies are simultaneously subject to conduct requirement consultations in the UK, amplifying the systemic significance of the regime's early decisions.
On the Ground
Competition law and technology regulatory practices are the primary areas activated, with firms advising both Google and third-party complainants or beneficiaries of the conduct requirements. Work includes regulatory notification drafting in response to the CMA consultation, compliance gap analysis memos assessing how proposed requirements interact with existing platform policies, and licence condition summaries mapping the proposed conduct requirements against Google's current default agreements with device manufacturers. A trainee on this type of matter would assist with drafting submissions to the CMA consultation, preparing chronology documents tracking the regulatory timeline, and indexing relevant CMA decisions, call-for-evidence responses, and committed undertakings into a structured reference bundle.
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