| Preliminary | Final |
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Preliminary measures note 2In the EU as of today and in the EEA following the incorporation of Regulation (EU) 2022/1925 into the Agreement on the European Economic Area. | Final measures note 1In the EU as of today and in the EEA following the incorporation of Regulation (EU) 2022/1925 into the Agreement on the European Economic Area. |
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| Not present in the earlier text. | Final measures note 2In other words, any undertaking that has submitted the application form specified in section 5.4.1. |
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| Not present in the earlier text. | Final measures note 3“Restrictive measures or other sanctions” should include economic and trade sanctions adopted on the basis of Article 29 of the Treaty on European Union or Article 215 of the Treaty on the Functioning of the European Union, as well as any other applicable law prohibiting, directly or indirectly, the conclusion of contracts for provision of services with that undertaking. For example, these include measures such as those imposed under Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 229, 31.07.2014, pages 1 – 11 or under Council Decision (CFSP) 2016/849 of 27 May 2016 concerning restrictive measures against the Democratic People’s Republic of Korea and repealing Decision 2013/183/CFSP, OJ L 141, 28.5.2016, pages 79 – 124. |
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| Not present in the earlier text. | Final measures note 4Transfers of personal data on the basis of an adequacy decision of the Commission adopted under Article 45 of Regulation (EU) 2016/679 do not require any additional safeguards. Adequacy decisions are made publicly available in the Official Journal and on the Commission’s website here: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en |
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| Not present in the earlier text. | Final measures note 5See https://ec.europa.eu/eurostat/web/nuts, last accessed on 29 June 2026. |
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Preliminary measures note 3See https://s2geometry.io/devguide/s2cell_hierarchy.html. | Not present in the final text. |
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Preliminary measures note 4An s2_cell of level seven corresponds to an area between 3 175km² and 6 530km², see official documentation https://s2geometry.io/resources/s2cell_statistics. | Not present in the final text. |
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| Not present in the earlier text. | Final measures note 6For the avoidance of doubt, the permitted purpose only extends to optimising or improving grounding systems and search capabilities for AI chatbots. Training of the general purpose LLM underlying the AI chatbot is excluded from the permitted purpose. |
| Preliminary | Final |
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Preliminary measures note 5Third-party online search engines’ processors or sub-processors are not considered third parties in this context. | Final measures note 7Third-party online search engines’ subcontractors acting as processors or authorised sub-processors are not considered third parties in this context. |
| Preliminary | Final |
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Preliminary measures note 6The least-privilege principle means that personnel, systems, or processes are granted only the minimum level of access permissions necessary to perform their assigned functions. | Final measures note 8The least-privilege principle means that personnel, systems, or processes are granted only the minimum level of access permissions necessary to perform their assigned functions. |
| Preliminary | Final |
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Preliminary measures note 7The need-to-know principle means that authorised personnel who have been granted access rights may access data only when required for the performance of their assigned tasks. | Final measures note 9The need-to-know principle means that authorised personnel who have been granted access rights may access data only when required for the performance of their assigned tasks. |
| Preliminary | Final |
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Preliminary measures note 8Article 33 of Regulation (EU) 2016/679 addresses the circumstances which give rise to a “[n]otification of a personal data breach to the supervisory authority” and Article 34 of that Regulation addresses the specific circumstances where a “[c]ommunication of a personal data breach to the data subject”. | Not present in the final text. |
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Preliminary measures note 9International Framework for Assurance Engagements issued by the International Auditing and Assurance Standards Board (IAASB), “Reasonable assurance engagements and limited assurance engagement”, paragraphs 14-16: available here: https://ifacweb.blob.core.windows.net/publicfiles/2024-08/IAASB-2023-2024-Handbook-Volume-4.pdf#page=46 A reasonable assurance engagement is defined as an assurance engagement in which the practitioner reduces assurance engagement risk to an acceptably low level in the circumstances of the engagement as the basis for a positive form of expression of the practitioner’s conclusion. In practice, reasonable assurance therefore refers to a high, but not absolute, level of assurance, obtained by reducing engagement risk to an acceptably low level. This allows the practitioner to express a positive conclusion regarding whether the subject matter meets the applicable criteria. By contrast, a limited assurance engagement is defined as an assurance engagement in which the practitioner reduces assurance engagement risk to a level that is acceptable in the circumstances of the engagement but where that risk is greater than for a reasonable assurance engagement, as the basis for a negative form of expression of the practitioner’s conclusion. Accordingly, limited assurance provides a lower level of assurance than reasonable assurance, because less extensive procedures are performed and the risk is not reduced to a sufficiently low level to meet reasonable assurance. The practitioner therefore expresses a negative conclusion, typically stating that nothing has come to their attention that causes them to believe the subject matter is materially misstated. | Final measures note 10International Framework for Assurance Engagements issued by the International Auditing and Assurance Standards Board (IESBA), “Reasonable assurance engagements and limited assurance engagement”, paragraphs 14-16: available here: https://ifacweb.blob.core.windows.net/publicfiles/2024-08/IAASB-2023-2024-Handbook-Volume-4.pdf#page=46 A reasonable assurance engagement is defined as an assurance engagement in which the practitioner reduces assurance engagement risk to an acceptably low level in the circumstances of the engagement as the basis for a positive form of expression of the practitioner’s conclusion. In practice, reasonable assurance therefore refers to a high, but not absolute, level of assurance, obtained by reducing engagement risk to an acceptably low level. This allows the practitioner to express a positive conclusion regarding whether the subject matter meets the applicable criteria. By contrast, a limited assurance engagement is defined as an assurance engagement in which the practitioner reduces assurance engagement risk to a level that is acceptable in the circumstances of the engagement but where that risk is greater than for a reasonable assurance engagement, as the basis for a negative form of expression of the practitioner’s conclusion. Accordingly, limited assurance provides a lower level of assurance than reasonable assurance, because less extensive procedures are performed and the risk is not reduced to a sufficiently low level to meet reasonable assurance. The practitioner therefore expresses a negative conclusion, typically stating that nothing has come to their attention that causes them to believe the subject matter is materially misstated. |
| Preliminary | Final |
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Preliminary measures note 10In this context, the targeted supplemental reasonable assurance engagement means a reasonable assurance engagement, performed in accordance with applicable international assurance standards, that is limited in scope to specific controls or systems and carried out for the purpose of addressing material gaps between existing assurance reports, certifications, or audit reports and the assurance objectives defined by the Commission. | Final measures note 11In this context, the targeted supplemental reasonable assurance engagement means a reasonable assurance engagement, performed in accordance with applicable international assurance standards, that is limited in scope to specific controls or systems and carried out for the purpose of addressing material gaps between existing assurance reports, certifications, or audit reports and the assurance objectives defined by the Commission. |
| Preliminary | Final |
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Preliminary measures note 11Data enrichment is permitted if it is limited to transformations that do not increase the risk of re-identification. | Final measures note 12Data enrichment is permitted if it is limited to transformations that do not increase the risk of re-identification. |
| Preliminary | Final |
|---|---|
Preliminary measures note 12The revenue from Alphabet’s commercial use of the data should at least include Google Search revenue, which is defined in this context as any revenue directly or indirectly attributable to the provision, operation, or monetisation of the Google Search service, including revenues generated through search advertising, intermediation of search-related traffic, and any other commercial activities deriving value from search queries or search-related user interactions. | Final measures note 13The revenue from Alphabet’s commercial use of the data should at least include Google Search revenue, which is defined in this context as any revenue directly or indirectly attributable to the provision, operation, or monetisation of the Google Search service, including revenues generated through search advertising, intermediation of search-related traffic, and any other commercial activities deriving value from search queries or search-related user interactions. |
| Preliminary | Final |
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Preliminary measures note 13Very large scale is being defined in this context as having more than 45 million monthly active end users established or located in the Union and an annual Union turnover equal to or above EUR 7.5 billion in each of the last three financial years, or an average market capitalisation or equivalent fair market value amounted to at least EUR 75 billion in the last financial year, calculated in line with Article 3(2)(a) and (b) of Regulation (EU) 2022/1925. | Final measures note 14Very large scale is being defined in this context as having more than 45 million monthly active end users established or located in the Union and an annual Union turnover equal to or above EUR 7.5 billion in each of the last three financial years, or an average market capitalisation or equivalent fair market value amounted to at least EUR 75 billion in the last financial year, calculated in line with Article 3(2)(a) and (b) of Regulation (EU) 2022/1925. |
| Preliminary | Final |
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Preliminary measures note 14Commission Recommendation of 6 May 2003 concerning the definition of micro, small and medium-sized enterprises, Official Journal L 124, 20/05/2003 P. 0036 - 004 | Final measures note 15Commission Recommendation of 6 May 2003 concerning the definition of micro, small and medium-sized enterprises, Official Journal L 124, 20/05/2003 P. 0036 - 004 |
| Preliminary | Final |
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Preliminary measures note 15This means that the resulting pricing terms should allow the beneficiary to obtain effective access to the Search Dataset to be able to optimise its search services without Alphabet maintaining or obtaining an unfair advantage. | Not present in the final text. |
| Preliminary | Final |
|---|---|
Preliminary measures note 16Including common costs arising from making the data available. | Final measures note 16Including common costs arising from making the data available. |
| Preliminary | Final |
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| Not present in the earlier text. | Final measures note 17No return on capital shall be due after a beneficiary has paid the fixed fee. |
| Preliminary | Final |
|---|---|
| Not present in the earlier text. | Final measures note 18For the purposes of calculating the fee Alphabet may charge for accessing the data samples B and C, as referenced in sections 5.1.2 and 5.1.3, Alphabet should only take into account recurring beneficiary-specific costs. |
| Preliminary | Final |
|---|---|
| Not present in the earlier text. | Final measures note 19For instance, where additional eligible beneficiaries obtain access after the initial intake period, those beneficiaries shall be subject to the same fixed component corresponding to one-off common costs as beneficiaries that obtained access earlier, subject only to adjustments reflecting objectively justified beneficiary-specific one-off costs. |
| Preliminary | Final |
|---|---|
| Not present in the earlier text. | Final measures note 20Alphabet shall indicate how the number of eligible beneficiaries, and any subsequent change thereof, will affect the final amount charged to each eligible beneficiary once known. |
| Preliminary | Final |
|---|---|
| Not present in the earlier text. | Final measures note 21“Third-party OSEs applying for eligibility” shall have the same meaning as “undertakings applying for eligibility” as defined in paragraph (3)(a). |