Search choice screen: the CMA’s revised test for AI assistants and rival search services
In short: The search choice screen the CMA proposes for Google’s Android devices and Chrome browser would be open to any search service, AI assistants included, that meets three eligibility criteria, the first of which would require AI summaries to attribute web content. Google would decide who qualifies every six months and send its reasons for any rejection to the CMA. Comments close at 5pm on 9 October 2026.
Search providers and AI assistants would have to apply to Google for a place on its search choice screen. UK users would use the screen to pick their default search service on Android phones and in Chrome. The Competition and Markets Authority (CMA) proposed the search choice screen on 23 September 2026. The CMA has also widened who can apply, dropping its earlier test that a service be marketed as a search engine, so an AI assistant that does the work of general search could qualify.
The CMA proposes the screen as a conduct requirement under Part 1 of the Digital Markets, Competition and Consumers Act 2024 (DMCCA 2024). The CMA designated Google with strategic market status (SMS) in general search services on 10 October 2025 and consulted on four conduct requirements on 28 January 2026. It imposed three of them in June 2026, as set out in the account of the Google search conduct requirements imposed on 3 and 17 June. The fourth, the User Choice conduct requirement, is the subject of the CMA’s second consultation.
The CMA relies on the open choices objective in section 19(7), that users can “choose freely and easily” between Google’s services and those of other undertakings, and on the permitted type in section 20(2)(e), which covers how options and default settings are presented. Section 24 requires a public consultation before the CMA imposes any conduct requirement; the CMA has chosen to consult a second time on the revised text.
Who could qualify for the search choice screen
A service would qualify for the search choice screen if Google finds that it meets three criteria in the draft User Choice conduct requirement. It must adequately address the full range of use cases of a general search service on a wide range of subjects, including by searching the web. It must also provide a functioning general search experience on the relevant access points, and a significant proportion of its UK users must consider it to provide a general search service.
The CMA’s proposed interpretative notes explain each criterion. A provider would not need its own search index; a syndicated index would do (note 30). The use cases are navigational, transactional, simple informational and more complex informational queries (note 29). A significant proportion of users means “a meaningful or non-trivial proportion” and “does not mean a majority” (note 42). A provider would have to meet minimum security requirements, which Google would specify (note 37). A service that gives generative AI summaries would have to attribute web content “clearly, accurately” and give users “a clear means to access that web content” (note 31).
| Eligibility test | What the CMA proposed in January 2026 | What the CMA proposes in September 2026 |
|---|---|---|
| Range of queries | “Adequately address the full range of use cases of a general search engine on a wide range of subjects by searching the web” | “Adequately address the full range of use cases of a general search service on a wide range of subjects, including by searching the web” |
| Technical performance | “Provide the expected general search experience for affected search access points” | “Provide a functioning general search experience for relevant search access points” |
| How the service is marketed | “Be operated and marketed with general search as a core and central part of the service” | Deleted |
| Attribution in AI summaries | No requirement | Web content must be “attributed clearly, accurately” with “a clear means to access that web content” (note 31) |
| Security | No requirement | “minimum security requirements” specified by Google (note 37) |
The CMA states that AI assistants “could in theory be able to be listed” if they meet the criteria (paragraph 4.14). Four respondents argued that AI services should be kept off the screen because the CMA had left Google’s own Gemini assistant outside the designated activity (paragraph 4.8). The CMA rejected the argument: its Gemini analysis rested on Google’s own products and commercial decisions, and its final decision of October 2025 had already identified AI assistants as an emerging competitive threat to Google’s general search service (paragraph 4.15).
How Google would decide eligibility for the search choice screen
Google, not the CMA, would decide which providers are eligible. Paragraph 12 of the draft User Choice conduct requirement would require Google to run “a clear, fair, robust and transparent process” every six months, by reference only to the eligibility criteria. Google would publish notice two weeks before each application window, decide within two months of the window opening, and write to each applicant and to the CMA, giving the CMA detailed reasoning for any rejection. No applicant would have to give Google confidential information to prove its eligibility (note 27), and an existing eligible provider would not need to reapply each round (note 28).
The CMA kept Google as decision-maker because Google already chooses the providers on its current Android choice screen and on the choice screen it runs under the EU Digital Markets Act (paragraphs 4.29 and 4.32). One respondent argued that the CMA should decide applications itself. The CMA responded by adding the procedural terms in paragraph 12 and the reporting duty. It proposes that paragraph 12 would take effect one month after imposition and the rest of the requirement within six months, so that Google can settle the first list of eligible providers before the screens go live (paragraph 4.112).
What UK users would see on Android and Chrome
UK users would see a search choice screen they cannot skip when they set up an Android device distributed after the requirement takes full effect, where the manufacturer has set Google Search as the default, or when they install Chrome afresh on a desktop, an iOS device or another Android device. Users who already have Chrome on those platforms would see the same screen at the first major Chrome update after the requirement takes full effect. After that, a skippable notification would take users to the screen at least once a year, unless they had deliberately chosen a default in the previous six months.
The screen would list eligible providers in random order and make users scroll through the full list before confirming. If more than 12 providers qualify, the CMA expects Google to show the five most popular and seven others chosen at random (note 13). Users could also try a provider for a trial period, which the CMA says should be no shorter than a week (note 18). The choice would then apply across the address bar, the search widget and the default search application.
Implications for search and AI assistant providers
The obligations would fall on Google alone. Under section 19(1) of the DMCCA 2024 the CMA may impose conduct requirements only on a designated undertaking. The eligibility criteria would still set the terms on which Google’s rivals can offer their services to UK users through Google’s own devices and browser. A provider that wants a place on the search choice screen would have to show Google that its service searches the web, handles the four query types, works on Android without crashing or returning errors, meets Google’s security specification and attributes the web content behind its AI answers.
Google would apply each of those tests. A provider that Google rejects would have Google’s written decision, and the CMA would hold Google’s reasons, but the draft contains no route for the provider to appeal to the CMA against the decision. The CMA would monitor through compliance reports every six months in the first year and annually after that, if the CMA is generally satisfied with Google’s compliance (paragraph 4.113). For a new entrant, the screen is one part of a wider set of UK launch questions, covered in the guide to regulatory perimeter and market entry advice.
Viewpoint
The attribution condition is the most consequential change in the draft. Under section 19(1) the CMA may impose conduct requirements only on a designated undertaking, and in general search that is Google. The CMA cannot impose a conduct requirement on an AI assistant that has not been designated. By making attribution a condition of eligibility for Google’s screen, the CMA would set that standard for every rival that wants the distribution the screen offers.
The CMA’s check on Google’s eligibility decisions would be the written reasons Google must send the CMA for each rejection. This arrangement follows the way Google already runs its Android screen, and the reports in the first year would show whether Google applies the criteria as the CMA intends. The consultation closes at 5pm on 9 October 2026, and the CMA expects to make its final decision by the end of the year.
Frequently asked questions
Could an AI assistant appear on Google’s search choice screen?
Yes, if it meets the eligibility criteria. The CMA’s revised proposal of 23 September 2026 deleted the test that a service be operated and marketed with general search as a core and central part of the service. An AI assistant would need to search the web, handle the full range of general search queries, work on the relevant access points and attribute web content in its AI summaries.
Who decides which providers appear on the search choice screen?
Google would decide, every six months, by reference only to the eligibility criteria. It would give two weeks’ notice of each application window, decide within two months of the window opening, and send the CMA detailed reasoning for any rejection. The draft conduct requirement contains no appeal to the CMA against Google’s decision.
When would the search choice screen take effect?
The CMA has not yet imposed the User Choice conduct requirement. Comments close at 5pm on 9 October 2026 and the CMA expects to decide by the end of 2026. Once imposed, the approval process would take effect after one month and the rest of the requirement within six months.
For advice on the CMA’s digital markets regime, or on what a search or AI service would need to show Google to qualify for the search choice screen, contact Rob Bratby at Bratby Law.
