Understanding Google’s SMS designation and the CMA’s next steps

Google’s Strategic Market Status (SMS) marks the beginning of a conversation about whether it's important to introduce specific rules to make sure competition works as it should. Now that they have been designated, the Competition and Markets Authority (CMA) can impose “conduct requirements” (CRs) on Google.

Under the Digital Markets, Competition and Consumer Act (DMCCA), the CMA can set certain rules, known as Conduct Requirements (CRs), for companies that are designated as having SMS. For the CMA to impose these requirements, they must meet three main criteria:

• They need to be proportionate

• They must fall under certain “permitted types” of requirements

• They should ultimately benefit consumers.

  
  

Before moving forward, the CMA needs to conduct public consultations on the proposed CRs. This means they will seek input from the public and stakeholders about what these requirements should look like.

The CMA published its plans in mid-July 2025. According to their roadmap, the CMA started consulting on possible CRs from autumn 2025, but from what we know they haven’t started the consultation process yet. They aim to impose these initial CRs and then issuing updated roadmaps in the first half of 2026.

What are the CRs?

Category 1 measures reflect the CMA’s initial priorities, anticipated to deliver the most immediate benefits for businesses and consumers. 

For publishers, the key CRs in Category 1 are a “fair ranking principles” obligation to ensure that Google ranks and presents search results in a fair and non-discriminatory manner, and CRs that would seek to ensure there is better transparency, attribution and choice for publishers in how their content, when it is collected for search, is used in Google’s AI services.

Category 2 comprises measures where the CMA believes there may be a case for action, but where certain issues require further consideration, and where potential interventions may be more complex to develop.

The CMA has placed into Category 2 CRs relating to fair treatment of competing specialised search services, fair and reasonable use of publisher content, and greater transparency of search advertising.

Next steps

While we wait for the CR consultation to take place, the Independent Media Association is preparing to bring Google to the negotiating table, backed by a strong set of research collected the collective bargaining coalition we’ve formed with the Independent Community News Network and the Independent Publishers Alliance.

We’re still in the midst of collecting Round 2 of research for these negotiations. Members and stakeholders can expect further updates in the New Year.

We cannot enter negotiations with Google until both Category 1 and Category 2 CRs are in place. We're requesting both financial and non-financial remedies during these negotiations. However, we need to wait for these CRs to clarify the government's expectations of Google before we can make our specific requests on top of what the government wants.