Why CMA SMS Comments Are Not Your Microsoft File
On 23 June 2026 the CMA published the non-confidential responses to its Microsoft business-software Invitation to Comment. Google called Microsoft “effectively a gatekeeper” that steers captive users toward its own cloud and AI. Killinghall Parish Council cited an unplanned £1,100 a year (ten Microsoft-hosted email accounts at £110) “to use Microsoft Teams effectively.” Microsoft said it “faces substantial competitive constraints across all five digital activities.” The proposed decision is due in October 2026. The statutory SMS deadline is 13 February 2027.
That’s the problem.
This is not a designation. It is an evidence file. The CMA has not found that Microsoft has strategic market status, and it has not written a remedy. It has put the complaints and the rebuttal on the same table. Your job is not to brief October as if it already happened. Your job is to know, on your own estate, where bundling, interoperability, and defaults already show up as license-position problems. This file is not the Wolfson-led UK class action, not the 2025 CISPE concessions, and not the end of volume discounts. Those are different clocks.
What the CMA actually published
The watchdog closed the Invitation to Comment on 4 June and, on 23 June, posted the non-confidential PDFs. Named respondents include Google, Killinghall Parish Council, Mozilla, and Microsoft. Publishing comments is not a finding.
Google’s sentence, in its own PDF, is that Microsoft’s control of the primary software ecosystem used by UK private and public customers, and its status as “the foundational gateway for enterprise workflows, means that it is effectively a gatekeeper and uses its entrenched position to steer captive users toward its own cloud and artificial intelligence (AI) solutions.” Google wants the CMA to treat listed-provider licensing discrimination as the first priority, and to restrict Copilot bundling into dominant applications.
Killinghall is a different object. Nine councillors and one clerk. They wanted Teams. Full functionality, they said, depended on Microsoft-hosted email. Ten licences at £110 a year. £1,100 unplanned. “We are concerned that Microsoft’s refusal to integrate fully with third-party products creates unnecessary additional costs for Parish Councils.” That is not a market-power theory. That is an interoperability bill.
Microsoft’s rebuttal, dated the same day the ITC closed, names the five activities (productivity suite, PC OS, server OS, relational database, security and identity) and refuses the “ecosystem” label. It “faces substantial competitive constraints across all five digital activities.” It names Google Workspace and LibreOffice, macOS and Linux, PostgreSQL and MySQL, Okta. “Microsoft’s commitment to openness and interoperability is real, deep and growing.” And: “AI is making competition more intense, not less.” Copilot, Microsoft said, is an admin-controlled, optional paid add-on.
The investigation opened on 14 May. The ITC asked about bundling, defaults, interoperability, and licensing that reduces cloud competition. The case page timetable puts a proposed decision in October 2026 and a final decision report, plus any SMS notice, in February 2027. Designation would allow interventions. That is scope, not a list of orders. Do not brief a remedy the CMA has not written.
Bundling, interoperability, and defaults are license-position problems
A published response is not a finding. Google’s “gatekeeper” sentence is Google’s sentence. Microsoft’s rebuttal is Microsoft’s sentence. Killinghall’s £1,100 is Killinghall’s invoice. None of those is your estate.
If that feels familiar, the problem is not your team’s maturity. SAM will open a seat export that says Microsoft 365 and a cloud bill that says compute. Those two files do not tell you which SKUs you chose, which arrived because they were the default, and which extra services you bought because a third-party tool would not talk to Teams. Traditional SAM tools collect seats and answer slowly. The gap is interpretation work. An analysis that arrives after the October proposed decision is a document. One that arrives during the next Microsoft meeting is a decision input.
The inquiry’s four themes are four ways a Microsoft position quietly grows.
Bundling is the SKU you did not pick line by line. Copilot embedding is the version of that question the CMA is reading, and the version Google asked it to future-proof. Ask whether the next E3, E5, or add-on conversation is a buy or a bundle that landed because it was already in the suite.
Interoperability is the extra Microsoft you bought so the Microsoft you already had would work. Killinghall had to purchase Exchange Online so Teams would work. Scale the mechanism, not the parish number.
Defaults are the product you got because the upgrade path pointed there. Mozilla’s filing is about Edge on Windows 11. Your version is the SKU or the Copilot attach that survived because nobody opted out. A buying decision is a person choosing a SKU, a quantity, and a price. A default is a catalog path that lands on the people who do nothing.
Licensing that reduces cloud competition is the fourth theme. Google wants listed-provider parity. Microsoft says the Cloud Market Investigation is out of date. This post will not invent a market total. Ask what this workload costs on Azure, and what the same workload costs somewhere else.
Do not let Microsoft frame the next meeting as “the CMA is still consulting, so nothing changes.” On the law, that sentence is fair. Yours is narrower: what are we running, which of it arrived as a bundle or a default, and where are we paying Microsoft twice because something else would not connect.
What to have before the October 2026 proposed decision
Do this in the next thirty days, as a decision pack rather than a project. The event is the next Microsoft conversation, not the proposed decision itself.
| What you produce | Why it changes the next conversation |
|---|---|
| A chosen-versus-bundled map | Copilot and suite SKUs you signed for versus SKUs that arrived in the bundle. Brief the mix you actually have. |
| Extra Microsoft bought so Microsoft would work | Add-ons and seats purchased because a third-party tool would not interoperate. Killinghall’s £1,100 is the parish version. List yours. Do not scale their invoice. |
| Defaults that survived without a PO | Tenant defaults, upgrade-path browsers, auto-renew add-ons, Copilot attach nobody opted out of. Name every SKU where inaction is treated as consent. |
| Same workload, two clouds, two license prices | The file includes licensing that reduces cloud competition. Your number is the delta on this estate. |
| A one-page note for the CIO and legal | This is the June evidence file, not a designation and not a remedy. What we take into the next placement. What we will not claim the CMA has already decided. |
Can a non-specialist brief the CIO in fifteen minutes from the pack you have today? If the answer is no, you do not have a CMA Microsoft SMS comments position. You have a library and a headline.
Do not brief Google’s “gatekeeper” line as if it were the CMA’s finding. It is a consultation response.
The decision layer, not another inventory
You already have discovery data, a seat export, and a cloud bill. The gap is turning that estate into a decision before October: which SKUs you chose, which arrived as a bundle or a default, and where you are paying extra Microsoft because something else would not connect. LICENSEWARE sits on the inventory and ITSM tools you already run. It is not a rip-and-replace SAM suite. It is a decision layer: what matters, why it matters now, what should happen next. Microsoft Deployment Manager is the pack that splits those SKUs; cost optimization is the commercial question, not another seat export. For European estates, digital sovereignty is a related constraint, not a substitute for the chosen-versus-bundled map.
If your current tools still need three weeks to turn “we have Microsoft 365” into chosen versus bundled, defaulted versus signed, extra Microsoft versus third-party, book a Software Intelligence Review. You can also start on the free plan and run the analysis on your own data.
The question to walk in with
Do not let the next meeting open as “has the CMA designated Microsoft.” It has not. The proposed decision is still ahead. The right question is: what are we actually running, which of it arrived as a bundle or a default, where are we paying Microsoft twice because a third-party product would not connect, and can we defend that number before October. That is a data question, not a sales question.
The vendor will walk in with a number. The only question is whether you have yours first: current, defensible, and tied to the contract in front of you.
FAQ
Did the CMA designate Microsoft with strategic market status? No. It published consultation responses. The case page puts a proposed decision in October 2026 and a statutory SMS deadline of 13 February 2027. Publishing comments is not a finding.
Is Killinghall’s £1,100 my exposure? No. It is one parish council’s unplanned annual cost so Teams would work: ten Microsoft email licences at £110. It is not your invoice.
Is this the same as the May SMS opening? No. May opened the file. 23 June published the evidence. The clock mark that matters now is the October proposed decision.
