Summary Of Google’s Self-Preferencing Practices Analyzed By The FCA

The FCA found Google has engaged in two distinct practices:

  • It used its dominant publisher ad server (Google Ad Manager, ex DFP) to favor its own AdX exchange.
    Their ad server favored the AdX bidding platform by sharing the price offered by competing SSP platforms. AdX then used this information to optimize the bidding process.
  •  It used AdX to improperly favor its publisher ad server (GAM, ex DFP).
    Google has imposed technical and contractual limitations on the use of the AdX platform through a third-party ad server which penalized both third-party technologies and publishers: “As a result, the modalities of interaction offered to third-party ad server clients were inferior to the modalities of interaction between DFP and AdX, which penalized both third-party SSPs and publisher clients.” 

What Did Google Commit To?

In February 2021, Google submitted five commitments to the FCA that are designed to be delivered not only in France, but some globally as well. Four are meant to prevent AdX favoritism and one is related to Google ad server favoritism.

This list of proposed commitments was accepted by the FCA with the expectation that Google must allow the restoration of fair competition.

Preventing AdX Favoritism

Google committed to delivering equal access to auction result information for all third-party SSPs and AdX buyers with a direct contractual relationship with GAM: 

  • Google will assure the transmission of the minimum bid to win (MBTW) in real-time and all other relevant data (paid solution+tests) to header bidders.
  • MBTW will be provided within 24 hours after the auction for publishers who do not wish to pay level 1.
  • Google committed to deliver equal access to auction result information to all third-party SSPs and AdX buyers with a direct contractual relationship with GAM for any header bidding-like approach.

Google committed to not restricting the ability of publishers using GAM to: 

  • negotiate special terms or pricing rules with third-party SSPs,
  • include or exclude specific buyers,
  • or set differentiated price floors for sensitive ad categories.

Google committed to not using third-party SSP prices to optimize bids if third-party SSPs cannot replicate, due to a lack of access to the same information. 

Google committed to enforcing a three-month notice period for any major change to GAM. 

Related to Google Ad Server Favoritism

Publishers using third-party ad servers will be able to benefit in real-time from AdX demand (two features: AdX Direct or Unsold Campaign Element Configuration). 

  • AdX Direct will allow publishers to have price competition between AdX and other SSPs without the floor price communicated to AdX buyers being set based on the winning price sent by the third-party ad server (two prices sent).
  • Google will waive any Ad Manager ad server fees incurred by EEA Publishers using a third-party ad server and who elect to use the Invited Campaign Item Configuration for the relevant impressions.
  • Google will make the AdX Direct Configuration and the Invited Campaign Element Configuration available to any ad inventory (for all formats – including video) using a third-party ad server.

Google’s Actions Implemented To Date

Three actions derived from the commitments have been communicated by Google directly to clients by email, through a blog article, and via updated help center articles.

Google Clients Can Access Minimum Bid To Win Data Transfer Files (Ad Manager 360) Upon Request Via Their Account Manager And At An Additional Cost

Publisher benefits:

  • Improved bidding algorithm for third-party SSPs, dynamic floor optimization capability.
  • Better bidding on all demand sources and increased revenue for GAM publishers. 

The Publisher Will Be Able To Set Pricing Rules That Apply Only To Creatives in Selected Sensitive Categories

Publisher benefits:

  • Improved brand safety and increased granularity in price management. 

Improved Interoperability Of Third-Party Ad Servers With the AdX Application For Approved European Economic Area (EEA) Publishers Only

If you choose to use a third-party ad server like Equativ, you might use Ad Manager to access real-time demand from Ad Exchange in two different ways:

1. Floor prices in Ad Exchange tags 

Publishers using a third-party ad server will be allowed to generate Ad Exchange tags to enable price competition between Ad Exchange and other SSPs.

The pricing floor feature in Ad Exchange tags will enable publishers to specify:

  • A floor price that is not passed to Ad Exchange bidders, but set as the minimum CPM threshold which Ad Exchange must beat,
  • And, if desired, you can specify a separate floor price (winning bid price, which is passed to Ad Exchange bidders).

Publisher benefits:

  • Differentiated management of floor prices and winning bid prices (header bidding or third-party ad server).
  • Ability to align all bidders to a single floor price from a third-party ad server and to a winning bid price, which is the best price between header bidding, a third-party ad server, and Google AdX.

2. Remnant line serving mode

Remnant line serving mode allows the publisher to send the winning price from its third-party ad server to trigger price competition in Ad Manager through a remnant line item.

The winning price the publisher sends from it third-party ad server can include header bidding and any other direct or indirect demand booked in your third-party ad server. This will not activate Ad Manager ad serving fees.

This setting is available for publishers who have been approved for remnant line item serving mode.

Publisher benefits:

  • Access to AdX demand for third-party ad servers, with AdX demand competing with third-party SSP demand.
  • Increased revenue for publishers using a third-party ad server.
  • End of GAM ad serving billing for winning campaigns from a third-party ad server or header bidding.
  • Reduced cost for publishers.

Maximizing Q4 Revenue Growth

At Equativ, we strongly support the FCA’s efforts to ensure these commitments will contribute to the restoration of fair competition.

As a third-party ad server, we are more than likely to conduct tests with publishers to access AdX demand and improve the competitive functioning of the market for ad servers and SSP platforms.

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