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Google’s Chrome commitments preserve core ad data advantages, UK filings show

Daniel Simon ·

Google’s legally binding promises to the UK competition regulator limit how it can remove third party cookies in Chrome, yet leave its biggest advertising advantages intact. A close reading of the undertakings accepted by the Competition and Markets Authority in February 2022 shows the commitments target browser conduct but do not require changes to Google’s control over logged-in user data across its properties.

The CMA’s document, “Commitments offered by Google to address competition concerns arising from the removal of third party cookies and other functionality,” accepted on 11 February 2022, binds Google to avoid self-preferencing when it ships Privacy Sandbox tools in Chrome. It also requires public disclosures of changes and gives rivals technical input rights through an industry testing process.

What the filings actually require

The undertakings restrict Google from combining data from Chrome with Google’s advertising businesses unless it is on an equal footing with others. They create a Monitoring Trustee, reporting to the CMA, to audit compliance. They also commit Google to address third party feedback during origin trials and to publish aggregate test results. These controls focus on browser APIs, user controls, and the mechanics of cookie deprecation.

They do not require Google to pool or share first party data from Search, YouTube, or Android. They do not limit the use of signed-in account data within Google’s ad stack. The CMA’s April 26, 2024 quarterly update noted Google’s decision to delay third party cookie deprecation and confirmed that the authority would continue to assess whether design choices foreclose rivals. The update did not expand the scope of data separation beyond the browser layer.

Industry research underscores the stakes for non Google publishers if open web targeting weakens. The Association of National Advertisers’ 2023 Programmatic Media Supply Chain Transparency Study found that only 36 cents of every dollar on open web programmatic reaches publishers on average. That dependency intensifies if advertisers consolidate spend in logged-in walled gardens that can promise deterministic targeting without third party cookies.

Who is affected and how

Independent ad tech firms face a structural asymmetry. They must adapt to Privacy Sandbox APIs and identity workarounds while competing against a platform that can rely on authentication and cross service signals. Publishers that lack scale in first party data see weaker yield if buyers shift toward Google’s own inventory and formats.

Google’s filings illustrate the economic tilt. In Alphabet’s Form 10 K for the year ended December 31, 2023, management disclosed continued reliance on Search and YouTube ads for a majority of revenue while highlighting ongoing Privacy Sandbox workstreams in Risk Factors and MD and A. Those sections flag regulatory uncertainty around changes to Chrome but do not contemplate sharing logged-in signals with the broader market.

What happens next is largely procedural but consequential. The CMA’s commitments remain in force for six years unless the authority releases Google from them. The regulator will continue to publish quarterly assessments and can seek enforcement through UK courts if it finds non compliance. For advertisers and publishers planning 2027 budgets, the filings indicate that cookie replacements will be supervised, but the competitive center of gravity remains inside Google’s first party ecosystem.