APMA member Genie Shopping has co-created and signed an Open Letter to the European Commission (EC) alongside a pan-European Comparison Shopping Services (CSS) coalition, warning of potential disruption to online retail from upcoming changes to Google’s search layout.
The warning follows a non-compliance decision and €460 million fine issued by the EC in July 2026 under Article 6(5) of the Digital Markets Act (DMA). Google has until 25 September 2026 to present a compliant product search layout that grants third-party CSS providers equivalent visibility to “Google Shopping”. Potential remedies under review range from opening an auction for the entire product search “box” to withdrawing specialised product units altogether – both of which carry significant commercial risks for retail brands and affiliate networks.
While the EU mandate applies across the European Economic Area (EEA), the UK Competition and Markets Authority (CMA) is closely monitoring outcomes to inform its own parallel roadmap under Strategic Market Status (SMS) rules.
Representing over 93,000 active European merchants and 74% of all third-party CSS clicks, the coalition is urging regulators to enforce explicit structural safeguards. The letter sets out key principles to prevent a return to pre-2017 gatekeeper dominance, protect direct merchant search visibility, and ensure equal competition rules apply across emerging Artificial Intelligence (AI) search surfaces.
Ciaron Dunne, Co-founder of Genie Ventures, said:
“Getting this regulatory remedy right for European retail brands is far more critical than rushing a flawed implementation. Any search layout that unwittingly forces retailers back to Google Shopping as a default option to preserve their visibility will severely harm an already challenging ecommerce landscape. We need structural guardrails that guarantee fair, open competition for retailers and price comparison website alike.”
The full open letter, outlining the group’s recommendations for a fair digital market, is published here.
