Google has updated its Google European Search Dataset Licensing Program page with details on the program. Google has been designated as a "gatekeeper" under the DMA and is thus legally required to share its search data with competing search engines to foster fair competition.
Google wrote that it refreshed the program overview, eligibility criteria, and application details.
The page explains that on:
September 6, 2023, the European Commission announced that Google has been designated as a gatekeeper under the Digital Markets Act (DMA). From March 2024, Google made available to qualifying recipients the relevant search dataset including appropriately anonymized data in order to comply with Art. 6(11) DMA. On July 16, 2026, the European Commission adopted measures further specifying how Google should comply with its obligations under Art. 6(11) DMA (the Measures), by making available to qualifying recipients a specified search dataset (the Search Dataset).
We did know this was coming by the way. The PDF measures document explains that:
(1) Google must provide access to a "Search Dataset," for both free and paid search results. This consists of anonymized online search data generated by end users on Google Search, specifically including:
- Ranking data
- Query data
- Click data
- View data
The data is available to eligible third-party online search engines (OSEs), including AI chatbots with search engine functionalities, operating in the EU and the European Economic Area (EEA). To be eligible, an applicant must prove they are an established company or a credible new entrant by meeting strict criteria, which is documented in the PDF.
There are primarily three conditions for sharing this data:
- FRAND Terms: The data must be licensed under Fair, Reasonable, and Non-Discriminatory (FRAND) pricing terms and conditions.
- Strict Anonymization: Alphabet is required to apply robust technical and contractual measures to ensure the data is fully anonymized and personal data is protected.
- Data Processing and Transfers: Alphabet must assess whether the applicant plans to process the data within the EEA or transfer it internationally. If the data is transferred outside the EEA to a country without an EU adequacy decision, Alphabet must ensure a level of data protection essentially equivalent to that guaranteed within the EEA, or reject the application.
Google wrote:
- The European Commission's Measures and associated criteria and requirements for accessing the Search Dataset: The Measures cover recipient eligibility, the scope of the data that should be made available, the frequency with which Google should make the data available, the fair, reasonable and non-discriminatory (FRAND) terms for access to such data, and the specific purposes for which the data can be used. Since recipients will receive personal data under the Measures, they also establish the associated liability for the receipt of such data and specify detailed technical and organizational requirements regarding data segregation, access control, and logging, all of which are subject to third-party auditing and reporting. Access to the data is also subject to recipients accepting Google's licensing terms. For more details, see the Measures.
- The Search Dataset: Comprises ranking, query, click, and view data from Google Search in the European Economic Area (EEA). More details can be found in the Measures and technical details will be provided to relevant applicants in due course in accordance with the Measures.
- FRAND pricing basis and process: Fees are determined on FRAND terms, which the Measures limit to the incremental costs of making the data available, together with a specified rate of return. Further details are set out in the Measures and will be provided to relevant applicants in due course in accordance with the Measures.
Google posted the eligibility criteria to receive search data which includes:
- Online search engine (OSE): The applicant must qualify as a provider of an online search engine as defined in Art. 2(6) DMA.
- Operating in the EEA: The applicant must operate within the EEA, meaning that their online search engine must be directed at users located in the EEA.
- No connection to state actors: The applicant must not be directly or indirectly under the operation or control of non-EEA state actors.
- No connection to an entity subject to restrictive measures or sanctions: The applicant must not be directly or indirectly under the operation or control of any natural or legal person subject to restrictive measures or sanctions under European Union (EU) law.
- Number of users and activity in the EU: The applicant must (i) either have provided OSE services in the EU for at least the last two consecutive years at the time of applying, or have been founded less than two years before applying but received more than EUR 50 million in capital investments; and (ii) have had at least 50,000 monthly average users of its OSE services in the EU in the past year.
If you think you can get access, you can fill out this form to request access.
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