The EU Digital Markets Act in 2026: What Has Changed?

From Regulation to Reality

The Digital Markets Act entered into force in May 2023 and became fully applicable in March 2024, giving designated gatekeepers six months to comply with its obligations. Two years into enforcement, the DMA has moved from theoretical regulation to practical reality, reshaping how the world’s largest tech platforms operate within the European single market. The results are a mix of genuine structural change, corporate resistance, creative compliance, and ongoing enforcement battles.

This analysis examines what has actually changed for European users, developers, and businesses as a result of the DMA’s implementation.

Gatekeeper Designations

The European Commission designated six companies as gatekeepers in September 2023: Alphabet (Google), Amazon, Apple, ByteDance (TikTok), Meta, and Microsoft. These designations cover 22 core platform services including search engines, app stores, messaging platforms, social networks, advertising services, web browsers, and operating systems.

Each gatekeeper faces specific obligations tailored to the services it provides. The goal is not to punish size but to prevent gatekeepers from leveraging their market position to disadvantage competitors, lock in users, or restrict business users’ access to their own customers.

Key Designations and Their Scope

• Alphabet: Google Search, Google Maps, Google Play, Google Shopping, YouTube, Google Chrome, Android, Google’s advertising services
• Apple: iOS, App Store, Safari
• Meta: Facebook, Instagram, WhatsApp, Messenger, Meta Marketplace, Meta’s advertising services
• Amazon: Amazon Marketplace, Amazon’s advertising services
• Microsoft: Windows, LinkedIn
• ByteDance: TikTok

Interoperability Mandates

The most structurally significant DMA provision is the interoperability requirement for messaging services. Article 7 requires gatekeepers operating number-independent interpersonal communication services to make their platforms interoperable with third-party messaging services upon request.

WhatsApp and Messenger Interoperability

Meta’s WhatsApp and Messenger were the primary targets of this provision. Under the DMA’s phased timeline:

• Phase 1 (2024): One-to-one text messaging and image sharing between WhatsApp/Messenger and requesting third-party services
• Phase 2 (2025): Group messaging and file sharing interoperability
• Phase 3 (2026): Voice and video calling interoperability

The technical implementation has been contentious. Meta has argued that maintaining end-to-end encryption across interoperable services presents fundamental security challenges. The Signal Protocol that underpins WhatsApp’s encryption was not designed for federation, and adapting it for cross-platform communication requires careful protocol engineering to avoid creating security vulnerabilities.

As of early 2026, several European messaging services have submitted interoperability requests, though the practical rollout has been slower than regulators hoped. The European Commission has pushed back against Meta’s proposed implementations where they add unnecessary friction or complexity that would discourage users from utilizing interoperability features.

Sideloading and Alternative App Stores on iOS

Perhaps the most visible consumer-facing DMA change is Apple’s grudging compliance with the requirement to allow third-party app stores and sideloading on iOS within the EU. Prior to the DMA, iPhone users could only install apps through Apple’s App Store, where Apple collected a 15 to 30 percent commission on all transactions.

What Has Changed

Apple introduced alternative app distribution in the EU through several mechanisms:

• Alternative app marketplaces: Third-party app stores can now operate on iOS in the EU. Epic Games, AltStore, and several European-developed marketplaces have launched.
• Sideloading via web distribution: Developers can distribute apps directly from their websites to iOS devices in the EU.
• Alternative payment systems: Apps can use third-party payment processors instead of Apple’s in-app purchase system.

The Core Technology Fee Controversy

Apple’s compliance has been aggressive in its literal adherence to the DMA while attempting to preserve its economic model. The most controversial element is the Core Technology Fee (CTF): a 0.50 EUR charge per first annual install beyond 1 million installs for apps distributed through alternative channels. This fee effectively makes alternative distribution prohibitively expensive for popular free apps, leading critics to call it “malicious compliance.”

The European Commission has investigated whether the CTF structure itself violates the DMA’s intent. Preliminary findings suggest that terms and conditions that make it impractical for developers to actually use the alternatives mandated by the DMA may constitute non-compliance. This enforcement action is ongoing and represents a critical test of whether the Commission can enforce the spirit of the law, not just its letter.

Default Browser and Search Engine Choice Screens

The DMA requires gatekeepers to present users with meaningful choice screens for default browsers and search engines on their operating systems. Both Google (Android) and Apple (iOS) now display choice screens during device setup in the EU.

Impact on Market Shares

Early data suggests that choice screens have had a measurable but modest impact on browser and search engine market shares within the EU:

• Browsers: Firefox, Brave, Vivaldi, and DuckDuckGo Browser have reported increases in EU installations since choice screens were implemented. However, Chrome and Safari retain dominant positions, partly because brand recognition heavily influences choice screen decisions.
• Search engines: DuckDuckGo, Ecosia, and Qwant have seen increased EU adoption. Google’s market share in EU search has declined by a few percentage points, though it remains above 90 percent in most member states.

The design of choice screens matters enormously. The Commission has pushed back against implementations where the gatekeeper’s own service is presented with visual advantages (larger buttons, pre-selected options, or prominent placement). The current consensus is that randomized presentation order with equal visual weight is the minimum standard.

Fines and Enforcement Actions

The Commission has not hesitated to use its enforcement powers. The DMA allows fines of up to 10 percent of global annual turnover for violations, rising to 20 percent for repeat offenses.

Notable Enforcement Actions

Several significant enforcement proceedings have been initiated or concluded:

• Apple: Investigated for the Core Technology Fee structure and for alleged non-compliance with interoperability requirements for iOS features (NFC access, default app settings). Multiple proceedings are active.
• Google: Investigated for self-preferencing in Google Search results and for the implementation of its choice screen. The Commission has examined whether Google’s compliance measures genuinely address the competitive concerns that motivated the DMA obligations.
• Meta: Under scrutiny for the pace and completeness of WhatsApp interoperability implementation, and for the “pay or consent” model it introduced in the EU where users must either pay a subscription fee or accept personalized advertising.

Fines have been issued in several cases, though some are under appeal. The amounts are significant enough to demonstrate that the Commission views the DMA as a regulation with teeth, not a set of voluntary guidelines.

Impact on European Tech Companies

The DMA was designed not only to constrain gatekeepers but also to create opportunities for European competitors. The results are mixed but directional:

• Browser and search alternatives: European browsers (Vivaldi, Brave’s European operations) and search engines (Ecosia, Qwant) have benefited from choice screens, though the gains are incremental rather than transformative.
• App developers: European app developers can now reach iOS users through alternative distribution channels with lower commission rates, though Apple’s CTF structure has limited adoption.
• Messaging services: European messaging apps like Threema and Wire could theoretically leverage WhatsApp interoperability, though the technical complexity of implementation has slowed progress.
• Data access: The DMA’s requirements for gatekeepers to provide business users with access to their own data have benefited European retailers on Amazon Marketplace and European advertisers using Google and Meta’s platforms.

What Remains Unresolved

Two years in, several critical questions remain open:

• Enforcement speed: The Commission’s investigation and enforcement processes take months to years. Gatekeepers have used this timeline to delay meaningful compliance while technically meeting deadlines.
• Creative compliance: Apple’s CTF is the most prominent example, but all gatekeepers have explored compliance approaches that satisfy the letter of the DMA while minimizing the competitive impact. The Commission’s ability to distinguish genuine from performative compliance will define the DMA’s long-term effectiveness.
• Global impact: The DMA applies only in the EU. Features and freedoms available to EU users are not necessarily available to users in other jurisdictions. Whether the DMA creates a “Brussels effect” that influences global platform behavior remains to be seen.
• AI integration: When the DMA was drafted, generative AI had not yet reached mainstream adoption. How DMA obligations apply to AI features integrated into gatekeeper platforms — Google’s AI Overviews in Search, Apple Intelligence on iOS, Meta’s AI assistants — is an emerging regulatory challenge.

The Bottom Line

The Digital Markets Act is the most ambitious piece of tech regulation any jurisdiction has enacted. Two years into enforcement, it has achieved structural changes that would have been unthinkable a decade ago: alternative app stores on iPhones, messaging interoperability requirements for WhatsApp, choice screens for browsers and search engines, and fines that make non-compliance expensive. The implementation has been messy, contested, and incomplete, which is exactly what enforcement of a regulation this ambitious looks like in practice. The DMA has not broken the gatekeepers’ market dominance, and it was never intended to. What it has done is establish that market dominance comes with legal obligations to openness, interoperability, and fair competition — principles that benefit European users, developers, and companies.