European Commission Proposes Binding Measures for Google to Share Search Data with Competitors and AI Chatbots Under the Digital Markets Act

The European Commission has officially issued preliminary findings to Alphabet Inc., the parent company of Google, outlining a series of proposed measures that would require the search giant to share vast quantities of search data with rival search engines and AI chatbot providers. This move, rooted in the enforcement of the Digital Markets Act (DMA), represents one of the most significant regulatory efforts to date aimed at dismantling the data advantages held by dominant technology "gatekeepers" within the European Union (EU) and the European Economic Area (EEA). Under the proposed framework, Google would be mandated to provide third-party competitors with access to four specific categories of anonymized data—ranking, query, click, and view data—on terms that are fair, reasonable, and non-discriminatory (FRAND).

The Commission’s proposal is designed to address the structural barriers to entry in the search market. By providing rivals with the same types of behavioral signals that Google uses to refine its own algorithms, the EU aims to foster a more competitive environment where smaller search engines and emerging AI-driven platforms can "optimise their search services and contest Google Search’s position." While the measures are currently in a preliminary stage, they signal a firm intention by Brussels to translate the broad principles of the DMA into specific, enforceable technical requirements.

The Scope of the Proposed Data Sharing Mandate

The heart of the Commission’s findings lies in Article 6(11) of the DMA, which specifically addresses the obligations of gatekeepers to provide third-party search engines with access to ranking, query, click, and view data. The Commission has identified six key areas where Google must implement changes to facilitate this data transfer. The primary objective is to ensure that competitors are not operating at a permanent disadvantage due to the lack of "clickstream" data—the massive volume of user interactions that allow search engines to understand intent and improve result relevance.

The four categories of data identified in the proposal are critical to the functioning of modern search technology:

1. Query Data: The specific terms and phrases entered by users.
2. Click Data: Information on which results users choose to interact with.
3. View Data: Data regarding which results were displayed to a user, even if they were not clicked (often referred to as impressions).
4. Ranking Data: Information regarding how results are positioned and prioritized within the search results page.

The proposal specifies that this data must be anonymized to protect user privacy, though the exact technical standards for this anonymization remain a point of significant contention. Furthermore, the data must be made available to any "eligible third party" operating a search engine in the EEA. Crucially, the Commission has clarified that this eligibility extends to AI chatbot providers, provided they meet the DMA’s definition of an online search engine.

The Inclusion of AI Chatbots and the Shift in Search Paradigms

One of the most consequential aspects of the Commission’s preliminary findings is the explicit inclusion of AI chatbots as eligible recipients of Google’s search data. This decision acknowledges the evolving nature of information retrieval, where users are increasingly turning to conversational interfaces like OpenAI’s ChatGPT, Microsoft’s Copilot, or Perplexity AI to find answers rather than traditional lists of links.

If these AI platforms qualify as search engines under the DMA, they could leverage Google’s anonymized data to improve their retrieval-augmented generation (RAG) systems. Currently, many AI search products rely on web crawling or partnerships with smaller search engines to ground their responses in real-time data. Access to Google’s query and click data would provide these AI models with a unprecedented look at human intent and preference, potentially allowing them to bridge the gap in accuracy and relevance that currently separates them from the market leader.

This development has profound implications for "citation visibility." In the current ecosystem, websites rely on search engine optimization (SEO) to appear in Google’s results. In an AI-driven future, the goal shifts to being cited as a source by a chatbot. If AI chatbots have access to Google’s ranking and click data, they may be better equipped to identify high-quality sources, fundamentally changing how traffic is routed across the internet.

Chronology of the Proceedings and Key Deadlines

The current proposal is the result of an investigation that began early in 2024. The timeline for the implementation of these measures is tight, reflecting the Commission’s desire for rapid enforcement of the DMA.

• January 27, 2024: The European Commission officially opened the Article 6(11) proceeding to investigate Google’s compliance with data-sharing obligations.
• April 16, 2024: The Commission issued its preliminary findings and proposed measures to Google.
• May 1, 2024: The deadline for the public consultation period. This allows competitors, privacy advocates, and other stakeholders to provide feedback on the proposed data-sharing methods, frequency of access, and pricing models.
• July 27, 2024: The anticipated date for the Commission’s final, binding decision.

Once the final decision is reached, Google will be legally required to implement the technical infrastructure necessary to share the data. Failure to comply with the final ruling could lead to severe financial penalties. Under the DMA, the Commission has the power to impose fines of up to 10% of a company’s total global turnover, which could rise to 20% in cases of repeated infringement.

Google’s Defense: Privacy, Security, and Regulatory Overreach

Google has responded to the preliminary findings with a vigorous defense, centering its arguments on user privacy and the potential for regulatory overreach. Clare Kelly, Senior Competition Counsel at Google, emphasized that the proposal could jeopardize the sensitive information of millions of European citizens.

"Hundreds of millions of Europeans trust Google with their most sensitive searches—including private questions about their health, family, and finances," Kelly stated. She argued that the Commission’s proposal would "force" the company to hand over this data to third parties under privacy protections that Google deems "dangerously ineffective." The company maintains that even with anonymization, the sheer volume and granularity of the data could allow for the re-identification of individuals, particularly when combined with other datasets held by third parties.

Beyond privacy concerns, Google has characterized the investigation as being influenced by its direct competitors. In statements provided to various media outlets, Google suggested that the probe is being driven "at least in part by OpenAI." The company claims that OpenAI and similar entities are seeking to "harvest data from Google in ways not anticipated by the drafters of the DMA." This framing suggests a legal battle ahead regarding whether the DMA was intended to subsidize the development of generative AI models by forcing the transfer of proprietary behavioral data.

The Broader Regulatory Landscape for Alphabet in the EU

The data-sharing mandate is only one of several regulatory fronts Google is currently navigating in Brussels. The European Commission is simultaneously pursuing other investigations under the DMA:

• Article 6(5) – Self-Preferencing: In 2025, the Commission sent preliminary findings regarding Google’s alleged self-preferencing of its own services (such as Google Shopping or Google Flights) in search results. Google has already begun testing changes to its search layout in Europe to address these concerns, including the introduction of "dedicated units" for comparison services.
• Article 6(7) – Interoperability: A separate proceeding is addressing the interoperability of third-party AI and software with the Android operating system. This aims to ensure that Google does not use its control over the mobile ecosystem to disadvantage rival AI developers.

These concurrent cases illustrate the Commission’s holistic approach to regulating Big Tech. By targeting data access, search display, and operating system interoperability, the EU is attempting to create a "level playing field" across the entire digital value chain.

Fact-Based Analysis: Implications for the Global Tech Market

The potential impact of the EU’s decision extends far beyond the borders of the European Economic Area. If Google is forced to build the technical infrastructure for large-scale data sharing in Europe, it sets a global precedent that other regulators—such as those in the United Kingdom, Japan, or even the United States—may choose to follow.

From a competitive standpoint, the proposal could be a boon for smaller search engines like DuckDuckGo, Qwant, and Ecosia. These services have long argued that they cannot compete with Google not because their algorithms are inferior, but because they lack the "virtuous cycle" of data that Google enjoys. With access to Google’s click and query data, these companies could significantly improve their relevance for local European queries.

However, the economic implications are complex. There are concerns regarding the "FRAND" terms of the data sharing. If the price set for data access is too high, only well-funded entities like Microsoft or OpenAI will be able to afford it, potentially consolidating power among a different set of tech giants rather than helping small startups. Conversely, if the price is too low, it may be viewed as an uncompensated taking of Google’s intellectual property and investment.

Furthermore, the technical challenge of "anonymization" remains a significant hurdle. Modern data science has shown that truly anonymizing behavioral data is incredibly difficult. If a data breach were to occur at a third-party recipient, the reputational and legal fallout would likely fall back on Google, creating a "security vs. competition" dilemma that the Commission will need to resolve before July.

Looking Toward the July Deadline

As the May 1 consultation deadline approaches, the tech industry is bracing for a period of intense lobbying and technical debate. The Commission must weigh the benefits of increased competition against the very real risks to user privacy and the potential for unintended consequences in the rapidly evolving AI sector.

The final decision, due by July 27, will be a watershed moment for the Digital Markets Act. It will determine whether the EU can successfully force a "gatekeeper" to share the crown jewels of its business model—its data—without compromising the security of its users or the stability of the digital economy. For AI developers and search practitioners, the outcome will define the next decade of how information is discovered and distributed in the European market.