The UK digital markets regime in action: the CMA’s first conduct requirements for Google and commitments for Apple and Google mobile platforms

The Digital Markets, Competition and Consumers Act 2024 (DMCCA) established the UK’s digital markets competition regime with the aim of creating a more level playing field for businesses and consumers in the UK that rely on digital markets dominated by large technology firms with substantial and entrenched market power.

To achieve this, the Competition and Markets Authority (CMA) has wide-ranging powers to regulate the conduct of large tech companies and to take targeted and proportionate action to improve competition in digital markets in the UK. This includes the power to decide whether a firm should be designated as having strategic market status (SMS) and therefore be subject to the rules of the SMS regime.

Only the very largest digital tech firms with a turnover of greater than £1 billion in the UK or £25 billion globally are subject to the SMS regime and can be designated as SMS in relation to a particular digital activity. Google was designated as having SMS in October 2025 in relation to general search and search advertising services, while Google and Apple were both designated as having SMS later that month in relation to their respective mobile platforms. In each case, the CMA found “substantial, entrenched market power” and a “position of strategic significance”.

SMS itself does not imply wrongdoing or compel the CMA to immediately impose conduct requirements. However, once a firm has been designated with SMS, the CMA can impose conduct requirements (CRs). These are tailored rules which set out how an SMS firm must conduct itself in relation to a digital activity where the CMA considers that doing so is proportionate and for the purposes of “fair dealing, open choices, or trust and transparency".

The CMA’s first proposed conduct requirements for Google

The CMA proposed its first CRs in January 2026 to improve how Google delivers search services, which handle 90% of general search queries in the UK and are a key gateway for businesses and consumers to access and navigate the internet.

The CMA is currently consulting on proposed CRs for Google in four key areas:

• User choice: requiring Google to display a choice screen on the Chrome browser and making existing default choice screens on Android mobiles a legal requirement, to allow users to make an informed choice about the search services they use and making it simple and quick for users to change their default search service at any time to better meet their needs and reduce barriers to switching to rival search services. The aim is to make switching easier and reduce barriers to entry for rival search providers.
• Publisher choice, transparency and attribution: giving publishers more choice and transparency over how their content is used in Google’s AI Overviews, allowing them to opt out of their content being used to power AI features such as AI Overviews or to train AI models outside Google Search, requiring Google to take practical steps to ensure publisher content is properly attributed in AI results, and clearly explaining how these arrangements operate. These measures are intended to give publishers a fairer deal over the use of their content and to help search service users verify sources in AI-generated results and build greater trust.
• Fair ranking: requiring Google to ensure that its approach to ranking search results is fair and transparent, including in AI Overviews and AI Mode, and to maintain an effective process for raising and investigating complaints about potential distortions caused by its ranking policies and procedures. Google must also provide appropriate information about ranking policies and material updates, subject to limits where disclosure would undermine legitimate aims or reveal commercially sensitive information.
• Data portability: placing Google’s existing data portability tool on a legal footing to ensure that users can continue to transfer search data between services or use third-party tools alongside Google’s products.

The CMA’s proposed commitments for Apple and Google mobile platforms

Further measures were proposed in February 2026 through the CMA’s publication of proposed commitments from Apple and Google to address the CMA’s concerns around improving the fairness of their app store processes and enhancing iOS interoperability, which would enable third-party apps to better access the features and functionality within Apple’s operating system. Those commitments had not yet been implemented at the date of the CMA’s announcement. The CMA was seeking views on them, with a proposed start date of 1 April 2026, subject to stakeholder feedback.

With the largest app economy in Europe, many UK businesses rely on Apple’s App Store and Google’s Play app to review and distribute their apps. However, these two companies’ mobile platforms occupy a duopolistic position in the UK mobile ecosystem (with around 90 - 100% of UK mobile devices running on Apple or Google’s mobile. The CMA has also defined those mobile platforms more broadly than app distribution alone, extending the designations to mobile operating systems, browsers and browser engines on smartphones and tablets. For app developers, Apple’s App Store is the only route to reach Apple users, while Google Play Store is by far the main distribution channel for reaching Android users. In practice, that makes these platforms critical routes to market for UK app developers and helps explain why the CMA has focused on fair treatment, transparency and interoperability. The CMA’s latest measures seek to redress this imbalance. The commitments secured from Apple and Google include:

• App review & ranking: ensuring that they review and rank apps on their app stores fairly, objectively and transparently and that they don’t give priority to their own apps over others that may compete with theirs.
• Data collection: ensuring that they safeguard the data collected from developers during app review and don’t unfairly use that data.
• Interoperability: allowing developers to request interoperability access to features and functionality within Apple’s iOS and iPadOS mobile operating systems and consider these requests fairly and objectively, enabling developers to better develop innovative and competing products for customers.

These commitments represent the first wave of changes since Apple and Google’s mobile platform SMS designations were made and further measures are expected in the near future. The commitments will take effect from 1 April 2026, subject to stakeholder views.

Both Apple and Google will be subject to continued monitoring and reporting by the CMA to ensure that they comply with these commitments; a failure to do so could result in the imposition of more formal CRs. It is worth noting that from a legal standpoint, those commitments made in February 2026 are not the same as formal conduct requirements under the DMCCA and sit outside the Act’s express statutory commitment mechanisms at this stage of the process.

What does this mean for businesses?

These developments will be particularly relevant to app developers, software providers, online publishers and consumer-facing digital businesses that depend materially on Google search, Apple’s App Store or Google Play Store for visibility, distribution or growth. They also show that the CMA is beginning to use its new digital markets powers to intervene in issues such as ranking, transparency, app review, distribution and interoperability.

Businesses affected by those issues should consider now whether to engage with the CMA, particularly where they face constraints around search visibility, app store treatment or access to platform functionality.