Industry News

PPA responds to CMA consultation on user choice in search

The PPA has responded to the CMA’s consultation on its proposed user choice conduct requirement for Google’s general search services.

This follows the CMA’s designation of Google with strategic market status in general search and search advertising in October 2025.

The requirement would give UK users a choice screen for selecting their search service. The CMA has now made its eligibility criteria “technology-neutral”, which means AI assistants such as ChatGPT and Perplexity could appear on the screen alongside traditional search engines.

The PPA supports the aim of greater user choice and stronger competition in a market where Google holds entrenched power. But similarities in how people use search engines and AI assistants hide a fundamental difference in how they treat publishers. Search has traditionally sent users to publishers’ sites. AI assistants largely answer queries directly, drawing on publishers’ content, often without permission, payment or referral traffic.

The CMA has already recognised this harm in the context of Google’s own AI features, which is why its publisher conduct requirement requires Google to offer publishers controls, transparency and attribution. Our response argues that if AI assistants are to benefit from distribution through the choice screen, they should meet at least equivalent standards. Otherwise, the choice screen risks steering users towards services that offer publishers fewer protections than Google, undermining the CMA’s own publisher measures.

Our key recommendations are:
  • Equivalent standards
    any provider relying materially on third-party content in AI responses should meet publisher safeguards at least equivalent to Google’s, as a condition of eligibility.

  • Meaningful attribution
    inline, clearly branded, deep-linked, individual and visible by default, with summaries that tease rather than substitute for the original content.

  • Outcome-based assessment
    evidence of actual referral traffic, not just interface design, should determine whether a provider meets the requirements.

  • Granular publisher controls: separate controls for indexing, AI answers, grounding, model training and agentic uses.

  • Transparency
    reporting on when content is used and cited, and the impressions, clicks and click-through rates it generates.

  • Publisher recognition
    a provider should be seen as a search service by a significant proportion of the publishers whose content it uses, not just by users.

  • A role for publishers
    Google should be required to consult publishers when assessing providers’ eligibility.

In the longer term, we’ve also asked the CMA to consider whether fair treatment of publishers should extend to other major discovery surfaces, such as Google Discover.

The CMA is expected to make its final decision by the end of the year. For more information, contact Eilidh Wilson at eilidh.wilson@ppa.co.uk.

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