The EU's first Digital Markets Act specification decision tells Google exactly how to hand rivals, and AI chatbots, its search query data

On 16 July 2026 the European Commission adopted the first specification decision in the Digital Markets Act's short history. Specification decisions are the Act's least discussed instrument and possibly its most consequential: rather than finding that a gatekeeper has broken a rule, the Commission writes down what compliance with the rule actually consists of. Case DMA.100209 does this for Article 6(11), the obligation on Alphabet to give third party search providers access to anonymised ranking, query, click and view data on fair, reasonable and non-discriminatory terms. The proceeding was opened on 27 January 2026 under Article 8(2).

The Commission's own developer portal sets out the shape of it. Eligible recipients are providers of online search engines in the EU or EEA, and the portal states plainly that AI chatbots with a search function qualify. An applicant must have operated in the EU for two or more consecutive years, or have been founded within the past two years with at least 50 million euros of capital investment behind it, and must have at least 50,000 monthly average EU users. It must process the data inside the EEA or under equivalent protection, and pass an independent audit of its safeguards. The data arrives anonymised by k-anonymity grouping, each user pooled with at least 1,000 others sharing location, device type and query language, and with a minimum seven day latency. Pricing is capped at incremental cost plus a reasonable return on capital. The compliance clock runs from adoption: eligibility forms and published beneficiary information at roughly one and a half months, licence templates and test data samples at two, a finalised anonymised dataset at four, and a completed pricing offer at six, which puts the price on the table in January 2027.

What has drawn attention in the second half of September is the reasoning rather than the timetable, as the non-confidential text has been read and written about. Reporting on that text says Alphabet proposed that a query enter the shared dataset only once 30 signed in users worldwide had issued it identically over 13 months, and that this would have stripped out between 90 and 100 per cent of unique queries; the Commission is reported to have replaced it with an entity based threshold of 50 users, removing between 10 and 20 per cent. If that account is right, it is the whole remedy in one parameter. A search index's competitive value is concentrated in the long tail, in the questions almost nobody asks, because those are exactly the ones a smaller rival cannot answer from its own traffic. A threshold set on query frequency is therefore not a privacy control with an incidental commercial effect; it is a dial that sets how much of the moat gets shared. dcentralmind has not read the decision text: the case PDF link published by the Commission's competition directorate redirects to a homepage, and the figures above are taken from secondary reporting and marked accordingly.

The reason this sits in a publication about decentralization rather than one about competition law is the kind of remedy it is. Most platform enforcement addresses conduct: stop self preferencing, stop bundling, offer a choice screen. Those leave the underlying asset exactly where it was. Article 6(11) goes at the asset. The accumulated record of what a few billion people typed and then clicked is not a by-product of the search engine, it is the search engine, and it is the one input a competitor cannot buy, build or reason its way around. Compelling access to it on cost based terms is an attempt to make a natural monopoly's core input contestable, which is a structural move dressed in procedural clothes.

Two things are worth watching rather than concluding. The first is whether anyone can actually use it: an EEA processing requirement, an audit, 50,000 monthly EU users and a 1,000 user anonymity floor together describe a fairly narrow set of beneficiaries, and the January 2027 price will decide whether the set is narrower still. The second is the chatbot point. By treating AI assistants with search functions as eligible recipients, the Commission has said that it regards the query moat as something the next interface generation would otherwise inherit intact. That is a judgement about where concentration is heading, made in a document about data formats.