The UK’s Competition and Markets Authority (CMA) recently closed a consultation on how Google Search operates as a commercial function. The consultation specifically focuses on how Google ranks search results and treats third-party publishers within its ecosystem.
Read more about the CMA consultations on Google’s Search services.
Many affiliate and partner marketing businesses are highly dependent on Google Search products for their livelihoods. Their services account for a significant share of tracked traffic through the affiliate marketing channel, so any modifications to them have the potential to substantially impact the industry. These products are also continuously changing, with AI-generated summaries a recent addition to the search engine’s results pages.
As well as ‘natural’ search listings, Google’s comparison shopping services are an important part of the affiliate landscape in the UK. According to the latest APMA State of the Nation report, CSS partners account for around 6% of the UK’s £1.7bn affiliate industry, or roughly £100m in commissions and payments.
The Affiliate & Partner Marketing Association (APMA) submitted a response to the consultation. In it, we stress the importance of maintaining fair access to search products for independent publishers. We also referenced the potential risks of Google-owned services having precedence while curtailing a publisher’s ability to generate sustainable revenue.
The UK affiliate industry is a growing and important part of the digital marketing landscape. Employing thousands of people across the country, it also accounts for close to 10% of all online retail spend. It also provides a revenue stream for popular consumer empowerment tools like price comparison, cashback, voucher, loyalty and reward sites.
The APMA submission
Here’s what we submitted in summary, with the full submission listed below:
- Fair ranking must apply across all search features. The CMA’s fair ranking principles should apply not only to traditional search results but also to emerging formats such as AI-generated summaries and integrated Google products.
- Independent publishers must retain meaningful visibility in search results. Affiliate, comparison and editorial publishers rely on referral traffic from search that they earn commissions on. If platform-owned products are prioritised over independent sources, such as affiliate sites, this risks undermining competition and consumer choice.
- Self-preferencing rules should apply clearly to vertically integrated services. Where Google operates its own products within search (such as comparison tools or shopping modules), safeguards should ensure these services are not given unfair advantages over third-party alternatives, like affiliate sites.
- Transparency around ranking and presentation is essential. Publishers and others operating in the digital industries, need clearer information about how search results are structured and how changes to ranking systems may affect visibility.
- The transition to AI-driven search must not foreclose publisher traffic. As AI-generated answers and summaries become more prominent, the underlying sources must remain visible, and that attribution supports continued referral traffic.
You can read the APMA submission in full here.
A huge thank you to Ciaron Dunne from Genie Ventures who was instrumental in helping us to shape this submission.
