German media regulator applies media law to AI search services in landmark ruling
July 14, 2026 10.40 Europe/London By Jörn Krieger

Germany’s media regulators have ruled for the first time that AI-powered search engines and chatbots fall under the country’s media law, marking a significant step in the regulation of generative AI services.

The Commission for Licensing and Supervision (ZAK), the joint regulatory body of Germany’s federal media authorities, has issued decisions concerning Google’s AI Overviews and AI search platform Perplexity following investigations led by the media authorities of Hamburg/Schleswig-Holstein and Berlin-Brandenburg.

The regulator concluded that Google’s AI Overviews and Perplexity’s AI-powered search and news services are subject to German media legislation because they generate their own content while also influencing the visibility of third-party media through the selection and presentation of links.

ZAK chairman Dr Thorsten Schmiege said the decisions establish that providers of AI search engines and chatbots must comply with German media law.

“AI search engines and chatbots are content providers, and we will consistently apply German media law to them from now on,” Schmiege said. “AI-generated answers constitute the providers’ own content, meaning the liability exemptions under the Digital Services Act do not apply. Anyone controlling the discoverability of content through the selection and placement of links must do so transparently. Otherwise, the diversity of journalistic media is put at risk.”

According to the regulator, Google’s AI Overviews display AI-generated summaries prominently at the top of search results, pushing conventional lists of web links further down the page. ZAK argues this disadvantages traditional search results and unlawfully discriminates against other content.

The authority also found that AI chatbots such as Perplexity act as media intermediaries when they attach sources, recommended reading or lists of links to AI-generated responses. By determining which third-party content users are likely to discover, such services become subject to rules designed to safeguard media plurality, it said.

The companies have the right to appeal the decisions.

The rulings are supported by two studies commissioned by the German media authorities. A legal opinion by Professors Jan Oster and Christoph Busch concludes that AI-generated responses should generally be regarded as the providers’ own content rather than merely reproducing information supplied by users. As a result, the Digital Services Act’s liability protections for intermediary services would not normally apply to AI-generated answers.

A separate study by Professor Dirk Lewandowski examined how generative AI is changing internet search and the potential consequences for media plurality. The report found that AI-generated answers increasingly replace traditional lists of links, reducing traffic to original publishers by between 18% and more than 50% in some studies, potentially undermining the business models of news organisations. It also concluded that the prominent placement of AI summaries could reduce the visibility of journalistic sources, although AI-generated summaries may also help users by presenting information from multiple perspectives in a more accessible format.

Beyond liability, the legal experts recommend clarifying how AI-powered search services should be regulated under European legislation including the Digital Services Act, the AI Act and the European Media Freedom Act. They also propose creating a dedicated legal category under German media law for AI search services, with obligations covering transparency, source attribution, ranking criteria and the non-discriminatory treatment of journalistic content.

The decisions are among the first attempts by a European media regulator to apply existing media pluralism rules directly to generative AI search services, signalling increased regulatory scrutiny of how AI platforms present information and shape public access to news.