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UK CMA Designates Google Search with Strategic Market Status: AI Overviews Are Now in Scope
The UK has formally designated Google Search with Strategic Market Status. Fair-ranking and consent rules are now on the table, and they could change how AI Overviews route traffic. Growth leaders should run an Answer Engine Optimization impact test, update consent tagging, and define KPIs for AI Overview–driven sessions and conversions.

Vicky
Oct 11, 2025
Breaking: Google Search gets Strategic Market Status in the UK
The United Kingdom’s Competition and Markets Authority (CMA) has confirmed that Google’s general search and search advertising services meet the legal tests for Strategic Market Status. This is the first major use of the UK’s new digital markets regime, and it lands squarely on the part of Google that drives the most discovery, revenue, and influence in the open web.
On October 10, 2025, the CMA said AI features that live inside search, including AI Overviews and AI Mode, fall within the designation, while the Gemini assistant does not for now. That distinction matters for anyone whose traffic or monetization depends on AI-shaped answers on Google results pages. See the regulator’s announcement for the scope and next steps in the official press release: CMA confirms SMS in search services.
What SMS means for AI Overviews and your traffic
Strategic Market Status does not accuse Google of wrongdoing. It gives the CMA authority to consult on targeted conduct requirements and pro‑competition interventions. In practice, that means the regulator can set rules for how search results and AI answers are ranked, attributed, and monetized, then enforce those rules with audits and penalties.
The immediate impact is about expectations and timing. The CMA has already outlined a roadmap of potential measures and has signaled it expects to consult on a first wave soon after designation, then revisit more complex issues through early 2026. The market will begin to price in likely rules before they arrive. Product managers at Google will plan UK‑specific changes to reduce risk, and publishers, advertisers, and rival search services will adjust their strategies. If you are responsible for growth, this is the moment to quantify, not just speculate.
The two rules that could reshape AI answers
Two ideas keep showing up in the CMA’s materials and public briefings. They are simple to state, but they carry big operational consequences for rankings, snippets, and AI‑generated summaries.
- Fair ranking principles
Fair ranking would require that Google’s presentation and ordering of results, including AI Overviews and any embedded modules, be non‑discriminatory and supported by a mechanism for raising issues. Think of three concrete levers:
- Self‑preferencing controls, like guardrails on how often Google‑owned verticals or properties are positioned above independent rivals for the same query intent.
- Evidence and auditability, such as clear criteria for when a link is elevated into the AI Overview citation block or when a commercial unit appears above organic.
- Redress processes, so affected businesses can trigger reviews when ranking behaviors depart from published principles.
If this lands, AI Overviews could show more consistent, quota‑like representation of high‑quality third‑party sources, and complaint‑driven corrections could arrive faster.
- Publisher consent and controls
The second lever is consent for using publisher content in AI outputs. The CMA has signaled interest in publisher controls, attribution, and choice over how content collected for Search is used in AI products. Its annual report lists both “fair ranking principles” and “publisher controls,” including use in AI services like AI Overviews, as early candidates for intervention: CMA annual report on fair ranking and publisher controls.
If explicit consent becomes the rule, Google will need a reliable way to respect opt‑ins and opt‑outs at the page or domain level. That could reduce AI Overview coverage for sites that deny permission, or it could push Google to expand incentives and clearer attribution so more publishers opt in.
Three likely scenarios for the UK search market
We do not know the exact text of future conduct requirements, but the direction is clear enough to plan. Here are three plausible scenarios and what each means for growth teams.
- Scenario A, more third‑party citations in AI Overviews: If fair ranking pushes Google to diversify AI Overview citations, expect a modest shift from zero‑click answers to click‑throughs on external links. Performance marketers should prepare to tag and attribute these clicks cleanly, because they may convert differently than classic blue‑link traffic.
- Scenario B, consent reduces AI summary coverage: If enough publishers opt out, Google may show fewer AI Overviews or present shorter summaries with more prominent links. Editorial teams should evaluate whether opting in with clear licensing and branding yields better outcomes than opting out completely.
- Scenario C, standard complaint and review process: If the CMA mandates a formal issue‑raising process with service‑level expectations, expect faster corrections for ranking anomalies. SEO leads should document high‑impact examples now, then be ready to file structured complaints once the mechanism is live.
Across all three scenarios, the UK becomes a live testbed for how AI answers can coexist with a fair, link‑driven web.
Run the AEO impact test this month
Answer Engine Optimization (AEO) focuses on visibility and clicks in AI‑generated answer surfaces, not just the classic ten blue links. You can run an AEO impact test in two weeks with your existing data and a light layer of measurement. For broader context on answer engines and growth, see our internal guide, the answer engine playbook for growth.
Step 1, baseline your current exposure
- Build a weekly panel of high‑value UK queries, at least 300 head and mid‑tail keywords that map to revenue.
- For each query, record whether an AI Overview appears, the number of citation slots, and which of your URLs, if any, are cited. Track the presence of follow‑up prompts that mention your brand or key features.
- If you lack time or tooling, teams use Upcite.ai to programmatically capture UK SERP snapshots and extract AI Overview coverage, cited URLs, and text fragments. That is faster than manual checks and supports before‑after testing.
Step 2, isolate traffic and behavior from AI Overview clicks
- Add a campaign‑level landing page rule in analytics that buckets sessions whose first pageview follows a Google Search referrer and lands on URLs frequently cited in AI Overviews for tracked queries.
- Create a synthetic segment that approximates AI Overview‑driven sessions using your panel, and compare engagement to classic organic sessions for the same queries.
Step 3, test content patterns that earn citations
- Rewrite two to three cornerstone pages to match how AI Overviews synthesize answers. Use crisp definitions, numbered steps, schema markup that clarifies entities and units, and original charts with alt text that states the takeaway.
- Publish side‑by‑side explainers with clear claims, sources, and pros‑cons tables. AI models often favor balanced, structured content for summary blocks.
Step 4, estimate incremental revenue
- Model how a 10 percent shift from zero‑click to click‑through on your top 50 queries would change pipeline. Sample a week of sessions from the AEO segment and apply your historical conversion rates or multi‑touch attribution assumptions.
- Document the sensitivity. Analysts and CFOs will ask for the range, not just the point estimate.
Update consent tagging and policies for UK traffic
If the CMA moves forward on publisher consent, you will want to be ready on day one. Most current controls for AI use of content are blunt, because they also affect snippets and rich results. The UK rules could introduce more surgical signals. For technical groundwork on robots and consent signaling, review our Cloudflare content signals playbook.
Start with a clear policy
- Define, by content type, whether you intend to allow use in AI Overviews in exchange for attribution and links. Consider commercial pages, evergreen guides, and news separately.
- Spell out conditions for opt‑in, such as mandatory citation, visible brand naming, and link placement within the AI Overview.
Audit today’s controls
- Inventory your robots directives, meta tags, and HTTP headers. Keep a list of pages where you already use max‑snippet, nosnippet, or paywall markup, and where those settings are part of your SEO strategy.
- Document where these controls hurt your search snippets so you can weigh any new AI‑specific consent tag against current performance.
Prepare for new consent signals
- Expect a page‑level signal that is easy to crawl and cache. Draw up an implementation plan that can roll out to your UK site sections first, then the rest of EMEA if relevant.
- Decide how you will enforce your policy. If AI Overviews use your content without the consent you signal, who on your team files the complaint and how will you measure remediation.
Define KPIs for AI Overview sessions and conversions
If you cannot measure it, you cannot improve it. Define a standard metric pack for AI Overview exposure and outcomes. You can begin with proxies and then refine once Google or analytics vendors add native fields.
Core exposure metrics
- AI Overview coverage rate, share of tracked queries that show an AI Overview.
- Citation share, percent of AI Overviews where your domain appears among citations.
- Slot quality, average position of your citation within the AI Overview block, including any repeat mentions within follow‑up prompts.
Session and conversion metrics
- AI Overview session share, sessions that begin on URLs frequently cited in AI Overviews for tracked queries. Use your panel and landing page rules to approximate.
- Assisted conversions, conversions where the first session in the path belongs to your AI Overview segment.
- Revenue per AI Overview session, broken out by branded versus non‑branded queries.
Quality and brand metrics
- Attribution clarity, whether the AI Overview includes your brand name next to the cited URL.
- Quote fidelity, how accurately the AI Overview reflects the content of the cited page. Track material misstatements and corrections over time.
Build a clean analytics pipeline for AEO
You do not need to wait for official fields to model AI Overview performance. A robust pipeline has three parts:
- A query panel that maps keywords to expected AI Overview behavior. This can be refreshed weekly.
- A landing page classifier that flags pages with a high likelihood of AI Overview referrals. Combine your panel with a rolling list of URLs detected as citations.
- A session stitcher that associates the above to downstream conversions, then compares against control cohorts that receive classic organic clicks for the same queries.
Add quality assurance. Spot‑check a sample of sessions each week by recreating the query and inspecting the SERP. When your URL is cited, capture a screenshot and text of the AI Overview. Store these artifacts with the session IDs for training and audits.
30‑60‑90 day plan for UK‑facing growth teams
30 days, learn and label
- Confirm your UK exposure. Segment organic traffic by country and isolate UK queries and pages.
- Stand up the query panel and first pass of the landing page classifier. Publish a simple weekly scorecard for leadership that shows AI Overview coverage and citation share.
- Align with legal and editorial on a draft consent policy. Identify priority sections for opt‑in or opt‑out.
60 days, test and target
- Ship two AEO content experiments in UK English, optimized for clarity, structure, and claims. Track whether citations increase on your top five queries.
- Negotiate attribution and link placement with your syndication partners. If they get cited in AI Overviews more often than your site, agree on canonical and rel policies to protect your brand and funnel.
- Draft a complaint playbook. Decide who files issues, what evidence is required, and how you will evaluate responses once the CMA opens consultation on ranking complaints. If your teams are also piloting Gemini‑based workflows, align with the Gemini agents pilot playbook.
90 days, commit and automate
- Finalize your consent tagging approach for the UK. Implement across the highest value pages first.
- Roll your AEO segment into media mix modeling and pipeline forecasting. Set quarterly targets for AI Overview session share and assisted conversions.
- Automate SERP capture and reporting, so your search and content teams receive a weekly alert when an AI Overview appears, changes, or disappears for a tracked query.
What to watch between now and early 2026
- Consultation timing and scope: The CMA indicated it expects to consult on initial interventions shortly after designation, then address more complex issues early in 2026. Watch for details on complaint processes, publisher consent signals, and any ranking transparency requirements.
- UK‑specific product tweaks from Google: Expect faster fixes for obvious ranking anomalies, clearer attribution in AI Overviews, and potential experiments that increase third‑party citation diversity in the UK.
- Choice screens and default settings: The roadmap signals interest in making it easier for users to choose different search services, including AI‑based assistants. If defaults change on browsers or Android setups, growth leaders should be ready to test incremental traffic from non‑Google sources.
Risks and mitigations
- Risk, over‑fitting to the UK: The UK may become more link‑friendly faster than other markets. Mitigation: keep your AEO playbook modular so you can localize for the US and EU without re‑writing everything.
- Risk, consent tagging backfires: Aggressive opt‑outs can suppress rich snippets. Mitigation: stage rollouts and monitor snippet loss before expanding.
- Risk, analytics blind spots: Without native fields for AI Overview referrals, your segment may misclassify some sessions. Mitigation: maintain a rotating validation sample and be explicit about uncertainty in leadership reports.
Conclusion, treat the UK as a controlled experiment
The CMA’s designation is not the end of the story, it is the beginning of rulemaking that could push AI Overviews toward more links, clearer consent, and faster correction when rankings go wrong. The winners will be teams that measure early, run disciplined AEO tests, and build consent and complaint readiness into their operating rhythm.
Your next steps are simple and high impact. Stand up an AEO measurement panel, draft a UK consent policy, and approve a KPI pack that isolates AI Overview sessions and assisted conversions. Use those signals to steer content, attribution, and investment decisions while the rules take shape. If you need help with weekly SERP capture and AI Overview tracking, Upcite.ai gives growth and SEO leaders a clean way to watch coverage, citations, and copy accuracy as this new regime comes into force.