CMA designates Google with strategic market status and opens conduct requirements consultation for general search services
The Competition and Markets Authority has designated Google as holding strategic market status (SMS) in the provision of general search and search advertising services. Following that designation, the CMA is now inviting comments on proposed conduct requirements (CRs), binding rules that will govern how Google operates its general search services in the UK. The consultation was published on 23 September 2026. The CMA's action follows powers conferred by the Digital Markets, Competition and Consumers Act, which created the SMS regime to address entrenched market power in digital sectors.
Why this matters
Google's SMS designation is the CMA's first major exercise of its new digital markets powers and sets the template for how conduct requirements will be structured across Big Tech. The conduct requirements consultation is the pivotal step before binding obligations are imposed, meaning Google's search and advertising practices in the UK could be materially constrained in the near term. The outcome will be watched closely by other platforms likely to face SMS investigations, and by advertisers and publishers who depend on Google's search ecosystem.
On the Ground
The SMS and conduct requirements framework activates competition law, regulatory compliance, and tech sector advisory work. Firms advising Google or rival platforms will be engaged on submissions to the consultation and challenging or shaping any final CRs. A trainee would be tasked with reviewing the proposed CRs, mapping them against existing Google product terms, and drafting a summary of key compliance obligations and risks for a partner briefing.
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