The new rules are designed to improve transparency and accountability in how Google organically ranks content in search results. They require Google to: 

• Apply objective and non-discriminatory ranking criteria. 

• Provide publishers with greater transparency about ranking policies and significant ranking changes. 

• Give advance notice of certain material changes to ranking systems. 

• Provide clearer complaints and dispute resolution processes for publishers. 

The rules will also apply to Google’s AI-powered search features, including AI Overviews and future generative search tools, but will not include Gemini. 

Overall, the PPA welcomes the CMA’s decision. Greater transparency and accountability in search rankings are essential for publishers, particularly as AI increasingly shapes how users discover content online. 

However, there are two aspects of the final decision that remain a concern: 

Experimentation exemption 

Following feedback from Google, the CMA has introduced an experimentation exemption for new search features. 

This means that new search features, including new AI-powered search products, may be exempt from parts of the Fair Ranking requirement for up to six months while Google tests and evaluates them. 

The CMA’s intention is to ensure the rules do not prevent innovation. However, many of the changes that have had the biggest impact on publisher visibility in recent years have come through the introduction of new Google products and features. 

The PPA is concerned that this exemption could allow significant changes to search experiences to operate outside key Fair Ranking protections for an extended period before they become subject to full scrutiny. 

Focus on process rather than outcomes 

The CMA has also decided that compliance with the Fair Ranking requirement will primarily be assessed by looking at Google’s ranking processes and policies, rather than the outcomes those processes produce. 

There remains a risk that a process could appear compliant on paper while still producing outcomes that disadvantage publishers. In those circumstances, Google may be able to argue that any negative impact was unintended, even where the practical effect is a significant loss of visibility for publisher content. 

Eilidh Wilson, Head of Policy & Public Affairs, PPA commented: “The PPA welcomes the CMA’s new Conduct Requirements on Google Search, which recognise the impact that sudden and opaque changes to search ranking can have on publishers. Trusted editorial brands depend on fair access to audiences, yet changes to Google’s algorithms can affect visibility, traffic, and revenue with little warning. The test now is implementation. 
 
The CMA’s decision to allow a 6-month experimentation exemption for new search features gives Google too much room to make changes with serious consequences for publishers before the Fair Ranking requirement fully applies. With AI-driven search rapidly reshaping how audiences discover and access trusted content, this is a significant concern. 

We are disappointed that the CMA has chosen to judge compliance by looking at processes, rather than ranking outcomes. The publishers we represent have consistently argued that fairness must be judged by its real-world effect on visibility, traffic, and audience access, not only by the stated intention behind a change. What appears neutral on paper can still downrank, disadvantage, or distort access to trusted editorial content. 

The UK’s specialist publishing sector plays a vital role in public life, employing around 55,000 people and contributing billions of pounds to the UK economy. We look forward to working constructively with the CMA to ensure these requirements give publishers genuine confidence, protect trusted editorial brands, and support a fairer value exchange between publishers and Google.” 

What happens next? 

Google will now have six months to implement the new requirements. 

The PPA will continue to engage with the CMA as the regime is rolled out and monitored. In particular, we will be paying close attention to how the experimentation exemption is used in practice and whether the new framework is effective in addressing harmful ranking outcomes for publishers. 

If you have any questions, please get in touch with Eilidh.wilson@ppa.co.uk