Google was ordered to rank UK search results fairly from June 2026. The law that ordered it does not require the public ever be shown proof.
Estimated reading time: 6 minutes
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In short. The Competition and Markets Authority's Fair Ranking Conduct Requirement compels Google to rank UK search results, including its AI Overviews, on "objective and non-discriminatory criteria" and to let publishers "effectively raise concerns." It took effect on 17 June 2026. The Digital Markets, Competition and Consumers Act 2024 that created this power requires Google to report to the regulator, not to the public: the first compliance report does not even cover a period ending before 17 December 2026, is not due to the CMA until 17 January 2027, and section 84(5) of the Act leaves publishing any of it to the CMA's discretion, with no deadline at all. Two documented mistakes: four stars.
The Competition and Markets Authority (CMA) is based at The Cabot, 25 Cabot Square, in Canary Wharf [1], and since October 2025 it has run the most consequential piece of UK competition law written this decade from there. The Digital Markets, Competition and Consumers Act 2024 gave the CMA power to designate the largest technology firms as holding "strategic market status" (SMS) and then impose bespoke "conduct requirements" on them, backed by fines that can reach 10% of a company's entire global turnover [2]. On 10 October 2025 the CMA designated Google as holding SMS in general search [3]. On 17 June 2026 it imposed the first of the substantive rules that designation was meant to unlock: a Fair Ranking Conduct Requirement [4]. The government sold this Act at Royal Assent as a way to "stop companies from withholding information consumers need to make good decisions" [5]. Whether anyone outside Google and the CMA can check that it is doing so is a different question, and the Act itself answers it.
The claims, tested
| The claim | What the Act and the CMA's own notices say | Verdict |
|---|---|---|
| The Fair Ranking Conduct Requirement "requires Google to: rank organic search results based on objective and non-discriminatory criteria, including in search generative AI features... enable publishers to effectively raise concerns" about ranking changes [6] | Section 84(1) of the Act requires Google to give the CMA a compliance report, not the public [2]. The Fair Ranking CR's own compliance reporting notice sets the first reporting period as 17 June to 17 December 2026, due to the CMA by 17 January 2027 [7] | Enforceable on paper, unverifiable in practice for at least four months from today |
| The Publisher Conduct Requirement "requires Google to: provide publishers with effective controls... provide publishers with clear and detailed metrics on user engagement with their search content in search generative AI features" [8] | The same section 84 architecture applies. The Publisher CR's compliance reporting notice sets its first reporting period as 3 June to 3 December 2026, due to the CMA by 3 January 2027 [9] | Same structural gap, second requirement |
| Google's compliance is checked and, implicitly, made visible | Section 84(5): "The CMA may give a notice to an undertaking requiring it to publish a compliance report or a summary of a compliance report" [10]. Both compliance notices repeat that the CMA merely "expects to issue a subsequent notice" after receiving a report, with no date attached to that expectation [7] [9] | "May", not "must": public disclosure is optional and open-ended by design |
| "If companies fail to comply with decisions made by the CMA, they could be subject to fines reaching tens of billions of pounds" [5] | Section 85(3) lets the CMA fine an undertaking for breaching a conduct requirement; section 86(4)(a) caps a fixed penalty at 10% of the worldwide turnover of the undertaking or, where relevant, its group [2]. Ten per cent of Alphabet's global turnover is, in plain terms, tens of billions of pounds | CLEARED: an accurate description of a real power |
The mistakes, counted
A rule that took effect in June has no evidence due until next year (1). The Fair Ranking and Publisher conduct requirements are not aspirations; they are legally binding obligations imposed under section 19 of the Act, with fines of up to 10% of global turnover sitting behind them [2] [6]. But the compliance architecture Parliament built runs on six month reporting cycles that only start from the day each requirement bites: the Fair Ranking CR's clock started 17 June 2026, and its first report is not due to the CMA until 17 January 2027 [7]; the Publisher CR's clock started 3 June 2026, first report due 3 January 2027 [9]. As of today, three months after both requirements took effect, no compliance report exists anywhere, including inside the CMA. A publisher whose traffic is hurt by an AI Overview this week has a right to raise the concern; nobody, including the regulator, has a right to a documented answer about the pattern of those concerns for months.
The Act does not require the CMA to ever show anyone the answer (2). Even the January report, when it lands, goes to the CMA, not the public. Section 84(5) of the Act gives the CMA the power to require publication: "The CMA may give a notice to an undertaking requiring it to publish a compliance report or a summary of a compliance report" [10]. "May" is doing real work in that sentence. Compare it with section 84(1), which says an undertaking "must provide the CMA with a compliance report" [10]: Parliament knew how to write a mandatory duty in this section and chose not to write one for public disclosure. Both compliance reporting notices confirm the CMA has not committed to a timetable either, stating only that it "expects to issue a subsequent notice" requiring publication, with the scope and format left for that future, undated notice to decide [7] [9]. A regime built to protect publishers and searchers from an unaccountable gatekeeper has, at its own accountability step, written itself an identical discretion.
Credit where due
The fine that backs this regime is not a paper tiger. Section 86(4)(a) caps a fixed penalty at 10% of an undertaking's worldwide group turnover [2], and against Alphabet's revenue that ceiling genuinely reaches into the tens of billions of pounds the Royal Assent press release promised [5]. The conduct requirements themselves are not vague either: the Fair Ranking CR names AI Overviews and AI Mode specifically as covered "search generative AI features" [6], and the Publisher CR requires clear, per-publisher engagement metrics rather than a general promise of transparency [8]. This is a real regulatory instrument pointed at a real and current problem. The fault found here is not that the CMA wrote weak rules; it is that the Act supplies no guaranteed moment at which anyone outside Google and the CMA gets to see whether those rules are working.
Verdict
Four stars, from two documented mistakes. A citizen reading the government's framing of this Act could reasonably think that once a conduct requirement is imposed, compliance becomes checkable. It is not, not yet and not by right. The reporting clock the Act itself sets means no evidence exists before January 2027 at the earliest, and the publication step that would let the people these rules exist to protect actually see it is a discretionary "may" with no date attached, not a promise. The power to fine Google tens of billions of pounds is real. Whether the public will ever be shown the evidence that would justify using it is, as things stand, entirely up to the regulator.
Sources
- Competition and Markets Authority, contact address. https://www.gov.uk/government/organisations/competition-and-markets-authority
- Digital Markets, Competition and Consumers Act 2024, section 86, legislation.gov.uk
- GOV.UK / Competition and Markets Authority, "Google's general search and search advertising services" (case page). https://www.gov.uk/cma-cases/googles-general-search-and-search-advertising-services
- Notice under section 19(1) of the Digital Markets, Competition and Consumers Act 2024 (the Act): Fair Ranking Conduct Requirement, CMA, 17 June 2026
- GOV.UK / Department for Business and Trade and Department for Science, Innovation and Technology, "Digital Markets, Competition and Consumers Act receives Royal Assent", 24 May 2024. https://www.gov.uk/government/news/digital-markets-competition-and-consumers-act-receives-royal-assent
- GOV.UK, "Google search: fair ranking conduct requirement". https://www.gov.uk/find-digital-markets-measures/google-search-fair-ranking-conduct-requirement
- Notice under section 84(3) of the Digital Markets, Competition and Consumers Act 2024 (the Act): Fair Ranking Conduct Requirement compliance reporting notice, CMA, 17 June 2026
- GOV.UK, "Google search: publisher conduct requirement". https://www.gov.uk/find-digital-markets-measures/google-search-publisher-conduct-requirement
- Notice under section 84(3) of the Digital Markets, Competition and Consumers Act 2024 (the Act): Publisher Conduct Requirement compliance reporting notice, CMA, 3 June 2026
- Digital Markets, Competition and Consumers Act 2024, section 84, legislation.gov.uk