Glossary · EU Competition Law DMA (Digital Markets Act)
The 2022 EU regulation imposing obligations on designated 'gatekeeper' platforms (Alphabet, Amazon, Apple, Booking, ByteDance, Meta, Microsoft) to ensure fair digital markets.
## What the DMA actually does
The Digital Markets Act (Regulation (EU) 2022/1925) is the EU's flagship competition regulation for digital markets. It entered into force in November 2022 and has applied since May 2023; the first gatekeepers were designated in September 2023 and had to comply by March 2024.
Unlike traditional competition law (which addresses anticompetitive behaviour after the fact), the DMA imposes ex ante obligations on a small set of designated "gatekeeper" platforms — companies whose market position gives them outsized influence over digital markets.
## Designated gatekeepers (as of 2026)
Six companies were designated as gatekeepers in September 2023, and a seventh in May 2024:
- **Alphabet** (Google) — for Search, YouTube, Maps, Chrome, Android, Google Play, Google Ads, Google Shopping
- **Amazon** — for Marketplace, Ads
- **Apple** — for App Store, iOS, Safari, iPadOS (added April 2024)
- **Meta** — for Facebook, Instagram, WhatsApp, Messenger, Ads (Facebook Marketplace was de-designated in April 2025)
- **Microsoft** — for Windows, LinkedIn
- **ByteDance** — for TikTok
- **Booking** — for Booking.com (designated May 2024)
The Commission decided in October 2024 not to designate X. In November 2025 it opened market investigations into whether Amazon Web Services and Microsoft Azure should be designated for cloud computing; in June 2026 it preliminarily concluded that both should be, with a final decision still pending at the time of writing.
## Core obligations on gatekeepers
The DMA imposes a list of specific do's and don'ts on gatekeepers (Articles 5 to 7), broadly grouped into:
**Interoperability requirements:**
- Messaging services must interoperate with third-party messengers on request (basic one-to-one features first; group chats and calls phased in later)
- Mobile operating systems must allow third-party app stores and sideloading
- Operating systems and browsers must show choice screens for the default browser and search engine
**Anti-self-preferencing:**
- Search engines cannot rank their own services above competitors
- App stores cannot favor their own apps over third-party apps
- Marketplaces cannot favor first-party listings
**Data restrictions:**
- Gatekeepers cannot combine personal data across different services without explicit user consent
- Gatekeepers cannot use business users' data to compete with them
- Users must be able to easily port data from gatekeeper services
**Transparency:**
- Detailed reporting on advertising metrics
- Clear disclosure of data use
- Transparent ranking factors
## Why the DMA matters for European tech
The DMA creates structural competitive opportunities for European alternatives:
**1. Choice screens** — Apple shows EU iPhone users a browser choice screen, and Android shows search-engine and browser choice screens. Smaller browsers and search engines, including European ones such as Qwant and Ecosia, now get a visible entry point, although Google remains dominant.
**2. App store competition** — iOS in the EU now allows alternative app stores. The Epic Games Store and AltStore PAL operate, while MacPaw closed its Setapp Mobile store in February 2026, citing Apple's business terms. Consumer adoption has been modest, but the structural change matters for app distribution economics.
**3. Messaging interoperability** — WhatsApp must interoperate with other end-to-end-encrypted messengers on request. The first third-party chats went live in November 2025 with BirdyChat and Haiket; group chats were not yet supported at launch, and voice and video calls are due by September 2027.
**4. Anti-self-preferencing** — Google may not favour its own vertical services (shopping, hotels, transport and similar) in Search results; in July 2026 the Commission fined Alphabet €460 million for continuing to do so.
For European businesses competing with gatekeeper platforms, the DMA creates real opportunities. For businesses building on gatekeeper platforms, it creates new disclosure and integration requirements.
## Penalty structure
DMA penalties are severe:
- **Up to 10% of global annual turnover** for non-compliance
- **Up to 20% of global annual turnover** for repeat infringements
- **Periodic penalty payments** of up to 5% of average daily turnover for ongoing non-compliance
- **Structural or behavioural remedies**, potentially including divestitures, after a market investigation into systematic non-compliance (at least three non-compliance decisions within eight years)
These penalties give the DMA real teeth. For a gatekeeper with €100B annual revenue, a 10% fine is €10B — meaningful even at gatekeeper scale.
## Enforcement actions in 2024-2026
The European Commission has been active:
- **Apple** — €500 million fine (April 2025) for App Store anti-steering rules, which Apple has appealed; specification decisions on iOS interoperability (March 2025); a separate procedure on its alternative-distribution terms and Core Technology Fee, followed by revised EU terms from October 2026
- **Meta** — €200 million fine (April 2025) for its binary "pay or consent" advertising model between March and November 2024
- **Alphabet** — preliminary findings (March 2025) on Google Search self-preferencing and Google Play anti-steering, followed by €890 million in fines in July 2026
- **Browser engines** — since iOS 17.4 (March 2024), browsers in the EU may use their own engines instead of WebKit
Enforcement has been steady but cautious. The Commission is establishing precedent carefully rather than rushing to maximum penalties.
## DMA's relationship to other EU regulations
The DMA is part of a broader EU digital regulation package:
- **GDPR** — protects individual privacy; DMA addresses platform power
- **DSA** (Digital Services Act) — companion regulation addressing content moderation and transparency
- **Data Act** — addresses access to non-personal industrial data
- **AI Act** — addresses AI-specific risks; DMA addresses competitive concerns about AI markets
For European businesses, navigating these overlapping frameworks requires explicit compliance mapping. The frameworks are complementary but operationally distinct.
## What 2026-2027 brings
- **Continued enforcement** — compliance with the 2025-2026 decisions and the remaining open proceedings
- **Cloud designations** — final decisions on whether AWS and Azure become gatekeepers for cloud computing; AI services are a stated enforcement priority
- **Interoperability implementation** — group chats and, by September 2027, voice and video calls for WhatsApp and Messenger
- **Court challenges** — Apple has appealed its €500 million fine to the EU General Court
- **DMA review** — the first review, published on 28 April 2026, found no need for legislative changes and named cloud and AI as priorities
The DMA is the most significant EU competition law update since the original EU competition framework was established. Its long-term impact on European digital markets is likely substantial.
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