Google Publishes Eligibility Rules and Timeline for EEA Search Data Licensing Under DMA

Google has updated its documentation for the European Search Dataset Licensing Program, providing detailed eligibility requirements, sample dataset options, audit procedures and key deadlines for competitors seeking access to search ranking, query, click and view data from Google Search in the European Economic Area.

The move implements the European Commission’s binding decision adopted in July under the Digital Markets Act, which requires Google to share anonymised search data with qualifying competitors, including AI chatbots that legally qualify as online search engines.

Licensing timeline and eligibility thresholds

Licensing agreements under the program will begin dispatching from September 17, with data samples becoming available starting November 16. The Commission plans to review the measures every two years.

To qualify, applicants must meet the DMA definition of an online search engine and target users within the EEA. They must not be controlled by non-EEA state actors or be subject to EU sanctions. All applicants must demonstrate an average of at least 50,000 monthly users of their search service in the EU over the past year. Additionally, they must have been providing search services in the EU for the past two consecutive years, or if they are recent entrants, have received over 50 million euros in capital investment.

Google says it will respond to expressions of interest within seven calendar days and may request supporting documents to verify eligibility.

Data samples and pricing structure

Eligible applicants may request samples before purchasing full dataset access. The program offers three sample tiers:

Dataset sample	Size	Fee	Availability
Free sample	1,000 rows	Free	From November 16
Synthetic dataset	Up to 10 million queries	Fee-based	From November 16
5% full dataset sample	5% of full dataset	Fee-based, FRAND terms	From November 16, after Level 1 audit

Fees for the dataset are set on fair, reasonable and non-discriminatory terms. According to the Commission’s measures, these fees are limited to the incremental costs of data provision plus a specified rate of return.

Audit requirements for larger datasets

Access to the 5% sample and the full dataset requires an independent assessment. While the smaller samples do not require an audit, Google still checks each applicant’s eligibility in advance.

An independent auditor examines the applicant’s technical setup, data storage and workflows. The Level 1 report must provide assurance that the applicant has credible plans to use the data for its own search product, and that its data protection controls are suitably designed.

To maintain access, recipients agree to ongoing monitoring by an independent assurance practitioner and must submit regular Level 2 reports. These reports test whether the controls are working in practice. The first report is due within six months of access being granted, with future reports due annually.

The Commission believes that keeping the data walled off inside the recipient’s own systems can meet the DMA’s anonymisation standard, but it is up to each applicant to demonstrate proper implementation.

Transparency and ongoing oversight

Google will maintain a public webpage listing all third-party search engines that access the dataset. This transparent list allows observers to see whether the data extends beyond traditional search engines to include qualifying AI chatbots covered under the decision.

The Level 1 audit requirement gates only the 5% sample and the full dataset, not the two smaller samples. This approach allows eligible companies to examine the free rows and the synthetic dataset before choosing to incur any audit costs.

Why this matters for Indian digital professionals

While the program directly targets EEA-based search engines and AI chatbots, the implementation details set a significant precedent for data access regulation globally. Indian digital marketers, SEO professionals and AI startups should watch how the DMA framework handles data portability and competitive access to search data, as similar regulatory conversations are emerging in India’s digital competition landscape.

The requirement for independent audits and ongoing compliance monitoring may also influence how future data-sharing mandates are structured in other jurisdictions, including India’s proposed Digital Competition Bill.

Source: Search Engine Journal – https://www.searchenginejournal.com/google-details-who-can-license-its-search-data-in-europe/587995/