This consultation represents one of the most significant interventions to date aimed at rebalancing the relationship between dominant platforms and content creators. If implemented effectively, the CMA’s regime could provide publishers with the transparency, control, and fairness that have long been absent from the search ecosystem.
In our response, we strongly welcome the CMA’s action to address entrenched market power in search and to introduce measures aimed at restoring a fairer value exchange between Google and publishers. However, we also emphasise that meaningful change will depend on the strength, specificity, and enforceability of the final CRs.
Sajeeda Merali, CEO, PPA said: “This is a welcome step from the CMA and an important opportunity to rebalance the relationship between publishers and Google. It rightly recognises the significant market power held within search and the dependence many publishers have on that gateway to reach audiences.
The proposed Fair Ranking Conduct Requirement acknowledges long-standing concerns about visibility and predictability, while the focus on AI-driven search reflects the real risks publishers face around content use, traffic, and commercial sustainability.
Any new opt-out mechanisms must be meaningful and enforceable, giving publishers genuine control and clear insight into how their content is used and its impact on revenue.
We remain committed to constructive engagement with Google and other platforms, but that relationship must be built on fairness and mutual respect, recognising the value publishers bring to the wider digital ecosystem.”
Key points from the PPA’s submission
Immediate work needed on a payment for content CR
We urge the CMA to begin developing a fair payment framework now alongside the implementation of the current CRs. Transparency and control are essential, but without a parallel pathway towards remuneration, publishers remain in a structurally unequal bargaining position.
Transparency must be a pre‑requisite for meaningful control
Publishers cannot exercise choice without clear visibility. Our submission stresses the need for:
- Real, disaggregated data on content crawling and use
- Clarity on whether content is used for training, fine‑tuning, or grounding
- Product‑specific engagement and traffic data across Search, AI Overviews, AI Mode, Discover and other surfaces
- Consistent tracking parameters that pass through to analytics tools such as GA4
Without this information, the controls risk becoming nominal rather than practical.
Controls must offer meaningful granularity
We highlight to the CMA that publishers must be able to opt out:
- Per feature (e.g., AI Overviews vs AI Mode)
- Per purpose (training, fine‑tuning, grounding)
The current grouping of all search generative AI features together is insufficient and continues to lock publishers into “all or nothing” decisions. We also stress the need for a clear and precise definition of “grounding” to ensure the associated controls work as intended.
Mandatory consent interaction with publishers
We recommend that Google be required to proactively seek publisher consent, for example via a consent banner in Search Console, rather than relying on publishers finding and interpreting publicly available information. Given the power imbalance, a passive opt‑out regime is not an adequate or fair mechanism.
Need for ongoing, independent compliance audits
We call for recurring, independently run audits rather than a single baseline assessment to test compliance, ensure content is not used where it has been opted out, and assess whether publishers are being harmed through punitive ranking effects.
Requirement for separate crawlers
We express strong concerns about Google’s proposal to retain a single unified crawler for both search indexing and AI-related content use. This approach undermines transparency, prevents publishers from exercising meaningful control, and leaves Google out of step with competitors who offer dedicated, segregated crawlers.
Protection against punitive ranking practices
While we welcome the Fair Ranking CR, we emphasise that:
- Google must not be allowed to punish publishers directly or indirectly for opting out
- Ranking signals from one surface (e.g., AI features) must not bleed into another (traditional search)
- Google should be required to test and prevent harmful “second‑order effects” and be subject to independent verification
Search engine choice screen must not include AI assistant tools
We agree with a browser‑level search engine choice screen, but we argue that AI assistant tools like ChatGPT and Perplexity should not be included. These tools are fundamentally different from search engines, operate outside existing licensing frameworks, and are currently beyond the scope of the CMA’s SMS designation.
Eilidh Wilson, Head of Policy & Public Affairs, PPA commented: “The PPA’s consultation response reflects the views of more than 200 publisher members, ranging from major consumer brands and business media to independent and specialist publishers. While there is broad support for the CMA’s proposed interventions, publishers remain cautious about whether they will deliver the outcomes publishers need.
Google remains the UK’s dominant search provider and is fundamental to the sustainability of trusted editorial brands. For publishers, transparency is a prerequisite for control: without clear, end-to-end insight into how content is crawled, used, and attributed, opt-out controls risk existing only in theory. That is why the CMA’s measures must deliver granular, per-feature controls over AI-driven search products, alongside safeguards that allow publishers to exercise those choices without fear of detriment.
If executed effectively, these measures could be transformative for the publishing sector, which employs over 55,000 people and contributes billions of pounds to the UK economy.”
Next steps
The PPA will continue to work closely with members and with the CMA to secure the refinements necessary to ensure these remedies deliver real, not theoretical, benefits.
You can read the PPA’s submission in full here.
If you’d like to discuss our submission or contribute further evidence, please contact Eilidh Wilson, Head of Policy and Public Affairs: eilidh.wilson@ppa.co.uk.
