CMA designates Google as holding ‘Strategic Market Status’ – what it means for our coalition and what’s next

On 10 October 2025, the UK Competition and Markets Authority (CMA) announced that Google now holds Strategic Market Status (SMS) under the Digital Markets, Competition and Consumers Act (DMCCA). In practice, this means the regulator is treating Google as a digital monopoly.

That designation opens a new chapter for our coalition* – we can now sit down with Google in formal negotiations. The CMA hasn’t released the accompanying Conduct Requirements yet, so the exact procedural rules (fairness, timelines, standards, dispute‑resolution mechanisms, etc.) are still unknown.

The Conduct Requirements are important – we don’t want Google to be negotiating in bad faith, or drag out negotiations, and generally make it more difficult to negotiate with them. Until those guidelines appear, we’re in a holding pattern: ready to negotiate, but waiting for the final rulebook. We expect to know what the guidelines are in January.

Where we stand

First‑round research completed – Thanks to the strong response from IMA members, we now have a solid evidence base to underpin our negotiating position.
Second‑round research in the works – We’re drafting a follow‑up survey to broaden participation and deepen the data set. Details on how IMA members can contribute will be shared soon.

What’s coming next

1. Weekly blog briefings

Starting this week, we’ll publish a short post each week covering:

Progress on the coalition’s collective‑bargaining efforts
International developments that could affect Google (eg US antitrust cases)
Parallel negotiations and regulatory moves in other jurisdictions

2. Fortnightly webinars (launching in the New Year)

A new webinar series will feature practitioners who have negotiated with Google and other major platforms worldwide. Each session will include:

An open, recorded segment for public viewing
A Chatham House‑style closed segment where members can discuss sensitive issues freely

3. Expanding the coalition network

We’re reaching out to additional trade associations, research bodies, and advocacy groups focused on digital regulation, lobbying, and big‑tech accountability. Some partnership talks remain confidential, but we’ll keep members updated as they develop.

The collective bargaining coalition will reconvene in early November. In the meantime, project leads are coordinating across the group to ensure consistent communication and alignment.

If you have any questions about collective bargaining, please reach out to us at [email protected].