The Competition and Markets Authority (CMA) has published Google’s formal response to the proposed designation of its search and advertising services under the Digital Markets, Competition and Consumers Act (DMCCA).

Alongside industry stakeholders, Google was expected to comment on the proposals and will have further opportunities to provide evidence and comments later in the year. As expected, Google challenged the CMA’s findings, particularly around the idea that it holds substantial and entrenched market power.

Key points from Google’s response

Google’s response covers a range of the CMA’s determinations on market power, switching, competition from AI, and the scope of regulation:

1. Default search position
   Google argues its default settings (eg. on Android) don’t block rivals, as users choose Google for quality, and notes that competitors like Microsoft have strong defaults (eg. Bing on Windows)
   
   
2. Switching is easy
   Google has claimed users can easily switch search engines, citing Android’s choice screen and behaviour on Windows, where Google isn’t the default but remains widely used
   
   
3. Market is dynamic
   Points to rapid AI developments (eg OpenAI and Perplexity adding ads) as evidence of a fast-changing market where Google’s power isn’t locked in long-term
   
   
4. Regulatory uncertainty
   Warns that the designation could create ‘substantial uncertainty… impacting UK businesses and consumers’

Despite Google seeking to reframe its position on market dominance, evidence from PPA members shows clear changes in traffic and audience behaviour following the rise of Google’s AI Overviews. This product further entrenches Google’s dominance and creates significant barriers for publishers operating in digital ecosystems.

The PPA has submitted evidence to the CMA, setting out recommendations for conduct requirements to ensure greater transparency, consent, and fairness. You can read more about these recommendations here.

If you have any questions, please get in touch with Eilidh Wilson, Head of Policy and Public Affairs, PPA eilidh.wilson@ppa.co.uk