About the Google European Search Dataset Licensing Program

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).

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.

Eligibility criteria to receive search data

To qualify in principle for a license, interested applicants must meet the following conditions specified in the Measures:

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.

Google may ask you to provide supporting documents to verify that you meet the above requirements.

Access to data samples before application

Before purchasing access to the Search Dataset, eligible applicants may request access to data samples, as follows:

Sample A: A 1,000-row dataset provided free of charge.
Sample B: A synthetic dataset of up to 10 million queries for a fee.
Sample C: A 5% sample of the Search Dataset for a fee.

More details on the data samples can be found at paragraphs 101–114 of the Measures and will be provided in due course. The data samples will be available as of November 16, 2026.

Technical and organizational requirements and third-party audits

The Measures require Google to provide personal data to recipients and only then rely on the recipients' internal data segregation as a guarantee that individuals won't be re-identified. In the European Commission's view, such internal data segregation on the recipients' side can achieve the anonymization standard required by the DMA. As such, the Measures require a significant technical and organizational commitment to data separation, control, and auditability. Among other things, this includes:

As a mandatory pre-requisite for access to Sample C and the Search Dataset itself, eligible applicants must undergo an independent assessment and provide a Level 1 reasonable assurance report. This report must be issued by an independent third-party auditor, qualified to inspect the applicant's technical infrastructure, storage systems, and workflows to verify compliance with the program's advanced security and privacy standards. For more details on the specific criteria and testing protocols required for the Level 1 reasonable assurance report, see paragraphs 69–72 and 82–86 of the Measures.
To maintain ongoing access to the Search Dataset, eligible recipients must submit to regular, continuous monitoring by an independent assurance practitioner and provide a Level 2 reasonable assurance report. This subsequent report, complying with the requirements set out at paragraphs 73 and 82–86 of the Measures, is required to verify sustained and uninterrupted compliance with these operational safeguards.

Further specificity on the precise technical and auditability measures required will be available in the data licensing agreement, which Google will provide to relevant applicants starting on September 17, 2026. The licensing agreement will also establish the overall contractual responsibilities recipients owe to Google and to third parties whose personal data they receive.

How to express interest in receiving the Search Dataset

If your organization meets the program's eligibility criteria and is prepared to invest in achieving the relevant technical, security, and auditability safeguards, fill out this form to request more information or to begin the application process. Google will respond to your request within 7 calendar days of receiving your expression of interest, as set out in paragraph 125 of the Measures.