The Google Ads class action enrolled you already. Now find the receipts

What the Tribunal actually certified on 5 August#

A fox does not argue with the weather, it reads it. On 5 August 2026 the weather changed for every UK business that has ever bought a Google search ad, and hardly anyone was asked to sign a thing. The Competition Appeal Tribunal granted a Collective Proceedings Order on an opt-out basis in case 1720/7/7/25, and the Google Ads class action it certified now carries a class of advertisers who never applied to join it.

The neutral citation is [2026] CAT 65 and the panel was Mr Justice Meade as chair, sitting with John Davies and Robert Herga. The class representative is Or Brook Class Representative Limited, a vehicle whose sole director and member is Dr Or Brook, a competition law academic, as ICLG reports. The class is defined as “All UK-domiciled Advertisers who, during the Relevant Period, paid for search advertising services provided by Google”, and the Relevant Period runs from 1 January 2011 to 15 April 2025, per PPC Land. Fourteen years and three months of spending, sitting inside a definition most advertisers have never read.

Six Google group companies are respondents: Alphabet Inc, Google LLC, Google Ireland Limited, Google UK Limited, Google Asia Pacific Pte Limited and Google Commerce Limited, all named on the Tribunal case page. The allegation is that Google's conduct let it charge supra-competitive prices for search advertising and cut the value advertisers got back from it.

Certification is a gate, not a verdict: it decides a claim is fit to be tried together, not that it is right. Google pushed for an opt-in class and lost, with the Tribunal finding almost nothing to be said in favour of opt-in, per ChannelX. On the day the ruling landed, Claims Journal reported that a Google spokesperson had not immediately responded to a request for comment, and no company statement on the Google Ads class action has surfaced since.

Opt-out means the Google Ads class action already includes you#

Opt-out inverts the usual shape of a claim, which is exactly why it catches people out. In opt-in proceedings you stand outside until you step in. Here you stand inside until you step out, and stepping out is a formal act with a date attached to it. Rule 82 of the Competition Appeal Tribunal Rules 2015 lets a class member opt out only in the manner and within the time the collective proceedings order specifies, and a late change of heart needs the Tribunal's permission.

That date does not exist yet. No opt-out deadline has been set in the Google Ads class action, so nothing has been lost and nothing has been chosen. A UK-domiciled advertiser who does absolutely nothing stays in the class. The only decision genuinely on the table this month is whether you will be ready when the notice finally arrives.

There is a second wrinkle worth naming early, and it is the one that will bite agencies hardest. Plenty of UK businesses never touched a Google Ads interface at all: an agency bought on their behalf, invoiced media plus a fee, and kept the account under its own manager login. The class as reported covers advertisers who paid for search advertising whether they purchased directly or through a media agency, per PPC Land, so who held the login and who was the advertiser are two separate questions. If your agency has changed twice since 2015, that is a hedgerow with three owners and no map.

The 14-year spend record most advertisers cannot produce#

Here is the unglamorous truth sitting at the centre of the Google Ads class action. Aggregate damages will be argued by economists, but any individual advertiser's eventual share of a distribution rests on what that advertiser actually spent, and most simply cannot show it. PPC reporting in this industry is built to look forwards. Dashboards refresh, agencies rotate, platforms retire report formats, and the spend record thins out behind you like a trail across wet ground.

Now walk the retrieval path as Google actually built it, because the defaults are quietly working against you. The Transactions page opens on the last three months and the filter has to be widened by hand, per Google Ads Help. Invoices, statements and payment receipts live in a separate Documents area and only appear once a month has closed, typically by the fifth business day of the following month, again per Google Ads Help. Campaign performance views default to the last 30 days and export as .csv, .xlsx or Google Sheets, per Google Ads Help.

Closed accounts are the quiet quarry#

The nastiest gap is the account nobody kept. Google cancels an account automatically after more than 15 months with no recorded spend, per Google Ads Help. You can still log in to a cancelled account, but the same documentation warns that access may not survive an extended period, and a cancelled account cannot be reached through the Google Ads API at all, so a scripted export comes back empty. If a 2013 account was shut in 2016, the honest answer may be that your bank statements are the only surviving record of that spend.

How to rebuild a ppc reporting trail that stands up#

So the Google Ads class action leaves advertisers a records job, not a legal one, and it is the sort of patient prowl that pays later. Building the case is the class representative's work, with an expert economist behind it. Yours is to hold a defensible spend record covering 1 January 2011 to 15 April 2025 before any deadline exists at all, because reconstruction under time pressure is where figures get rounded, and rounded figures get challenged.

This is where PPC reporting tools earn their keep, and also where they quietly fail. Most PPC reporting software connects to a live account and backfills only as far as the connector allows, which is fine for a two-year view and useless for the fourteen-year one the Google Ads class action turns on. Treat the tool as transport, not memory: export to files you own, store them where no agency contract can reach, and keep the raw exports beside any tidy summary built on top.

Then ask the agency, in writing, for specifics rather than reassurance: the customer ID of every account that has ever run for you, the invoices raised against your legal entity, media spend separated from fees, and the dates each account opened and closed. A good agency hands that over inside a week. A defensive one offers a summary, and a summary is not a record. Account access is layered too, and Google's own documentation notes that manager accounts sitting outside the paying hierarchy cannot see client billing at all, per Google Ads Help, so the phrase “we have access” deserves a follow-up question.

What happens next in the Google Ads class action#

Certification is the start of a long walk rather than the end of one, and the road from a Collective Proceedings Order to money in a bank account has several gates across it. Here is where the Google Ads class action goes next.

The immediate step is procedural. Antitrust Intelligence reports that the class representative was given 14 days to file a letter of formalisation covering the remaining details, including the exact class definition, limitation and continuing loss. Fountain Court Chambers, whose counsel appeared in the proceedings, records that the Tribunal rejected all four of Google's objections and that the damages period still needs defining before trial. The edges of the class can therefore still move, which is one more argument for holding your own numbers rather than waiting to be told which years count.

Keep the regulatory backdrop in a separate drawer, because it is a different process with a different purpose. On 10 October 2025 the Competition and Markets Authority designated Google as having strategic market status in general search and search advertising, noting that more than 90% of searches in the UK take place on its platform. The CMA was explicit that designation is not a finding of wrongdoing, and its conduct requirements, published through 2026 on the CMA case page, run entirely separately from this claim.

So what should you measure while you wait? Completeness, not performance. Count the accounts you have identified, the months you can evidence with a document rather than a screenshot, and the gaps you have written down and dated. It is a strange PPC reporting scorecard, and for the next few months it is the only one that speaks to the Google Ads class action at all. The rest of your paid search programme carries on regardless, and the same archive habit makes every SEO and GEO baseline sturdier while you are at it.

One honest caveat to close on, because the trail deserves a truthful end. The folkfox team is a marketing agency, not a law firm, and none of this is legal advice: it tells you what to gather and who to ask, not what to decide. What we can do is find the records, name what is missing, and hand you a spend file you could put in front of anybody. If you work somewhere heavily regulated such as FinTech, where account ownership and audit trails are already a board-level concern, that file is worth building whatever the Tribunal decides next.

Frequently asked questions#