Executive Summary

Powered by artificial intelligence (AI), answer engines represent the natural evolution of general search engines. They respond to user queries by performing search tasks on the users’ behalf.

In the European Union, the Digital Markets Act (DMA) shapes competition in the search engine market. Gatekeepers providing general search engines must comply with obligations that influence market dynamics at both the development (upstream) and deployment (downstream) stages.

This report proposes a framework to safeguard competition in answer engines under the DMA. It analyses how answer engines operate and assesses the DMA’s impacts upstream and downstream.

Answer engines remain nascent and highly dynamic. Intense competition at both upstream and downstream levels drives continuous innovation, benefiting users and content creators alike. Users gain faster access to high-quality information, reducing search costs, while content creators attract engaged audiences and valuable traffic.

The DMA, however, could affect these dynamics. At the upstream level, Article 6(12) requires gatekeepers to offer fair, reasonable, and non-discriminatory access conditions to services. Questions remain about whether this requirement extends to data access. However, such an interpretation would be inappropriate. It could hinder market entry by raising data acquisition costs and risk misapplying the DMA to matters that copyright law may cover—an AI-related copyright issue that remains unsettled. At the downstream level, Article 6(5) restricts how gatekeepers may promote their own services within general search engines. The absence of a clear definition of “services” creates legal uncertainty, which could limit market contestability by impacting both gatekeepers’ and rivals’ ability and incentive to compete in the answer engine market. This uncertainty may negatively affect prices, quality, choice, and innovation for users and content creators.

Against this backdrop, the Commission should pursue pro-competitive actions. First, it should use the DMA’s instruments to clarify and specify access conditions and self-preferencing obligations, preserving competition upstream and downstream. Second, it should promote cross-regulatory consistency through cooperation and advocacy.