Open Letter: Call of e-recruitment services for intervention against Google’s favouring of Google for Jobs by European online recruitment services

Ms Margrethe Vestager

Commissioner for Competition 
European Commission
Rue de la Loi
B – 1049 Brussels

August 13th, 2019

Re:     Our concerns in the ongoing investigation 
in Case AT.40592 – Google for Jobs

Dear Commissioner Vestager,

We are writing to you as European online recruitment services of all sizes and origins to share our collective view that Google abuses its market dominance as a general search service by favouring its own online recruitment service, Google for Jobs, in its general search results pages

Our services enable candidates to compare millions of job postings across Europe. Unlike Google for Jobs, our companies employ thousands of specialists to provide high-quality services to recruiters and job seekers alike. We strive to help job seekers in finding the jobs that suit them best and to assist recruiters in discovering the candidates that perfectly match open positions. Some of us have decided to participate in Google for Jobs, that is, to provide our unique job content to Google. However, this decision has been taken only as a result of the anti-competitive pressure Google is imposing on us. It does not change our common concern that Google for Jobsis: (i) a competing online recruitment service; and (ii) benefiting from an undue advantage, vis-à-vis its competitors – us.

Most of us, the signatories to this letter, wholeheartedly supported the Commission’s decision in October 2018 to open preliminary investigations into Google’s conduct and send out numerous requests for information. We welcome that the Commission is continuing to pursue this case, as evidenced by the second round of requests for information that have recently been sent out. 

Based on the overall data available to us, we are optimistic that the replies to these requests will paint a clear picture of what Google is attempting to achieve: to use its search monopoly as a lever to dominate yet another online industry.To us, the parallels with the Google Search (Shopping)case are overwhelming.

Contrary to what Google wants us to believe, Google for Jobsis clearly competing with us on our markets and not operating in a vertical relationship with us.When Google aggregates the job listings that “job boards” typically post on their websites, it acts as an online recruitment service in the form of a “job aggregator” or “job metasearch service”. However, there is more to it than that; Google also directly offers its services to recruiters and thus fulfils the typical functions of a job board. In doing so, Google is attempting to circumvent and ultimately serve as a substitute for other job boards. In fact, behind our backs, Google’s sales teams are already actively and directly approaching our customers and sourcing recruiters as key clients. The anti-competitive nature of Google’s favouring ofGoogle for Jobs is not altered by the fact that Google currently does not charge a fee for displaying job search results and “allows” competing online recruitment services to participate in the process. In fact, the offering of such a “free” service is one of Google’s oldest ploys to quickly gain content and market share at no cost toitself, only for it to then subsequently change its business from a free to a paid-inclusions model. Thus, such a predatory offer to display job search results for free only aggravates the negative effects of Google for Jobs.

Despite the Commission’s investigation, Google has continued the aggressive roll out of Google for Jobsin major markets such as Germany and France. The only change made by Google, as an attempt to address the industry’s competition concerns, was to offer some form of “rival links” carousel. For good reasons, the Commission has already rejected similar proposed solutions in the process of reviewing the merits of the three commitment proposals offered by Google during the Google Search (Shopping)investigation. Unlike the box with results from Google for Jobs (the “Jobs Unit”), the “rival links” carousel does not contain any information that relates to the search query and would therefore appear relevant to the job seeker. It is apparent that such meaningless links cannot, by their very nature, ensure equal treatment of online recruitment services on Google’s general search results pages.

The reality is that the entire ecosystem we helped to build over the past few decades is under attack from Google.  This is not positive disruption by Google; it is negative destruction to the detriment of Google’s competitors and, as a result, users of this ecosystem. More than 70% of job seekers commence their search on Google,[1]Google therefore controls access to this user group. By forcing us to make available our job content to Google for Jobsas a condition for us being given access to this user group, Google is de factoobliging us to hand over our core company assets to our strongest rival – for free. Considering further the indirect network effects present in this market, this will inevitably make Google for Jobsstronger and its competition weaker. No job search platform can compete with Google without having a complete database to rival Google’s.[2]Regrettably, this development will be to the detriment of job seekers and recruiters alike. Once there is only one or a handful of online recruitment services left in this market, prices will go up, and quality of those services will go down. By then, as evidenced in the market for comparison shopping services, it will be almost impossible to re-establish new competition. 

Whilst we embrace competition, its challenges must be fair;nobody can match the reach of Google’s general search service. In such circumstances, we feel that the unprecedented nature of Google’s ability to occupy and control this indispensable gateway in the Internet ecosystem, should not allow Google to usurp the entire online value chain. The Internet does not belong to Google. Platform competition should be based on the merits of each individual company, in every online market. Simply “taking” a market by occupying general search is anathema to the notion of competition on the merits. By favouring Google for Jobsin its search results, Google ensures that its jobs service achieves the same market penetration as Google Search and that it is shielded from effective competition from other, better quality and more relevant, online recruitment servicesThis conduct raises barriers to market entry and deters innovation to the detriment of job seekers and recruiters alike. By way of example:

  • Nobody looking for a job online gets past the Jobs Unit of Google for Jobs. This is particularly so when the user starts a search on a mobile device, on which the Jobs Unit dominates the entire screen. These large boxes render any scrolling down to the generic results of competing services irrelevant and unlikely, not least because any click on an icon within the Jobs Unit opens an even richer job search page of Google for Jobs
  • Having launched its online recruitment service in Germany in May 2019, as in other EU countries (Spain, France and the UK), Google for Jobsinstantly became market leader in visibility. According to independent analysts, for 92.9% of all Google for Jobsintegrations in Germany, the Jobs Unit was ranked on position 1 of the general search results pages.[3]The same analysts note that the picture in England[4]and Spain[5]is similar.
  • The actual number of generic search results on general search results pages has decreased since Google introduced the Jobs Unit; the decrease has been from ten to eight (or nine, depending on whether Google displays other answer boxes). As such, the Jobs Unit usurps some results for competing services (and sends them to the second page, i.e. rendering such services virtually invisible to users).
  • In addition to no longer receiving the traffic they deserve, participating online recruitment services receive now only “ready-to-apply candidates”.  Such candidates are no longer interested in researching other job opportunities on participating recruitment sites. This user traffic is of lower relevance to participating recruitment sites as these job seekers have already completed the most important parts of their candidate journey, i.e. searching for and comparing different job offers online. Competing recruitment sites that nonetheless participate in Google for Jobstherefore provide content to Google for Jobs on the one hand, but, on the other, are not able to display the full spectrum of their offers to job seekers arriving from Google for JobsParticipating recruitment sites are even forced to design the pages on which they describe a specific role that is open in a way that directs users back to Google for Jobs instead of keeping them on the rival service for further searches.
  • Through targeted job alerts, job seekers are actively and constantly kept within Google for Jobsand, as a result, only need to exit the Google universe for the final stage of their job search experience – the application (at least for now). Google’s many recruiting functionalities have nothing to do with a general search service anymore. 

Google for Jobsis part of a broader Google strategy to take over the entire candidate journey and the direct relationships between competing online recruitment services and candidates.In parallel with Google for Jobs, Google has launched two complementary products in the jobs / recruiting space: Cloud Talent Solution[6]and Hire[7]. It will therefore not be long before Google starts offering bundled services incorporating the functionalities of all these different products and giving its entire job search and candidate management universe a competitive head-start using its unprecedented search and data power.[8]

Considering the – in our view – prima facie competition law infringements briefly set out in this letter, we would like to encourage the Commission to use all available tools, including interim measures, to bring the infringements to an end. We respectfully remind the Commission of the direct and negative impact that Google’s conduct has on the European labour markets, which are very sensitive in nature. In our view, the cases Google Search (Shopping)(Case AT.39740) and Microsoft (Tying)(Cases AT.37792 and AT.39530) can serve as a blueprint for finding that Google is abusing its market dominance in general search services to the detriment of consumers and competitors alike. Regrettably, our market cannot wait until the new Commissioner has settled in. 

Yours sincerely,


Doug Monro 
CEO, Co-Founder
Adzuna (United Kingdom)

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Frederico Formigal
Alerta Emprego (Portugal)

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Graham Everitt
Ray Duggins

Best Jobs Online (UK)

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Dan-Gabriel Puica
Bestjobs (Romania)

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Peter Hallmann
cesar® Jobs (Germany)

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Michael Weideneder
Convigo GmbH (Germany)


Povilas Kytra
CEO Baltics
CV Market Group (Estonia, Latvia, Lithuania)

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Dritan Mezini 
CEO (Albania)


Christian Göttsch
Klaus Mantel

Directors                 Experteer (Germany)

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Jorge Guelbenzu Lapresta
Managing Director
Infoempleo (Spain)

Sonja Ćetković
Employment and HR websites Director
Infostud 3 doo (Serbia)


Stephan Marzen
Intermedia (Germany)

Kaare Danielsen 
Jobindex (Denmark)


Lukas Erlebach
CEO, Co-Founder
Joblift (Germany)

Plamen Voushev 
CEO (Bulgaria)


Wolfgang Achilles

Matthias Reineke
Jobware (Germany)

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Torsten Hein
Alexander Roß

Kimeta (Germany)

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Ismo Kurri
Managing Director
LAURA Recruitment (Finland)


Tomaž Gorjup
Mojedelo (Slovenia)

Davor Odobašić
Executive Director (Bosnia & Herzegovina)

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Željko Hudoletnjak
CEO (Croatia)

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Przemek Gacek
CEO (Poland)

István Martis 
CEO (Hungary)




[1]CareerBuilder Candidate Behavior Research (2015). Also, Google’s CEO Sundar Pichai stated during the Google I/O 2017: “We realized the first step for many people when they start looking for a job is searching on Google”.

[2]As observed by the U.S. Department of Justice (see U.S. District Court of the Southern District of New York of 22thMarch 2011 in The Authors Guild et al. v Google(Case 05 Civ. 8136 (DC)): “The seller of an incomplete database … cannot compete effectively with the seller of a comprehensive product”.

[6]Within the Google Cloud Platform, Google launched the Cloud Talent Solution. Based on machine learning and AI, the Cloud Talent Solution offers an engine for two-sided matching of candidates and jobs. It targets the talent industry – that is, job boards, Applicant Tracking Software providers (“ATSs”), career site providers and staffing agencies.

[7]Within its G Suite, Google launched Hire. This is a recruiting app for employers to identify, evaluate and hire candidates.

[8]Cloud Talent Solutionwill enable Google to improve its search and matching algorithms by gathering important data. Competitors do not have access to such data sources, and Google’s use of the talent industry’s very own sensitive data sets could likely be used to make Google even stronger. 

Hirewill help Google sell its bundle of job board and ATS to recruiters, serving as a one-stop shop for all their recruiting needs. Google is already advertising that companies can get the “[posting of] unlimited jobs to Google” as a benefit of using Hire(see

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