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The EU Digital Markets Act (DMA) is a competition framework for large digital platforms designated as “gatekeepers.” If your company sells through, advertises on, builds for, or integrates with a covered service, the law may create rights to access certain data, request interoperability, obtain advertising information, and direct customers to offers outside that platform. The exact right depends on the designated service, your role, and the relevant DMA obligation.
What is the EU Digital Markets Act?
The DMA is Regulation (EU) 2022/1925. It entered into force on 1 November 2022 and became applicable on 2 May 2023. Its purpose is to make digital markets fairer and more contestable by imposing specific obligations and prohibitions on designated gatekeepers.
The regulation applies to providers of designated core platform services, not automatically to every large technology company or every product offered by a designated company. It complements ordinary EU competition law; it does not replace investigations under Articles 101 and 102 of the Treaty on the Functioning of the European Union or national competition rules.
The European Commission is the DMA’s sole enforcer. Its institutional overview states: “The European Commission is the sole enforcer of the DMA.”
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Which companies are gatekeepers under the DMA?
Designation is made at provider-and-service level. A company can be designated for some core platform services while other products remain outside the DMA’s gatekeeper obligations.
Quantitative thresholds create a presumption, not an automatic designation
The Commission’s criteria use three tests: significant impact on the EU internal market, an important gateway between business users and end users, and an entrenched and durable position. Meeting the numerical indicators creates a rebuttable presumption that those conditions are met. The Commission can also make a qualitative assessment.
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| Indicator | Commission criterion | Important qualification |
|---|---|---|
| EU turnover | At least €7.5 billion in each of the last three financial years | Alternative to the market-capitalisation test; it supports a presumption rather than an automatic final designation. |
| Market value | Average market capitalisation or fair market value of at least €75 billion | Alternative to the turnover test; the Commission still assesses the other designation conditions. |
| End users | At least 45 million monthly active end users in the EU | The user thresholds are assessed over three financial years for the entrenched-position test. |
| Business users | At least 10,000 yearly active business users in the EU | Measured for the relevant core platform service and subject to the same three-year entrenched-position assessment. |
The Commission’s end-of-2025 snapshot
In its 2025 DMA reporting period, the Commission reported seven gatekeepers and 23 designated core platform services. The list below is a dated snapshot, not a permanent register; check the Commission’s live Gatekeepers Portal for current service-level status.
| Gatekeeper | Examples of designated core platform services reported by the Commission |
|---|---|
| Alphabet | Google Search, Google Play, Google Maps, YouTube and Android Mobile |
| Amazon | Amazon Marketplace and Amazon Advertising |
| Apple | App Store, iOS, Safari and iPadOS |
| Booking | Booking.com |
| ByteDance | TikTok |
| Meta | Facebook, Instagram, WhatsApp, Messenger and Meta Ads |
| Microsoft | LinkedIn and Windows PC OS |
Designation can change as the Commission receives notifications, completes market investigations or updates its decisions. Do not assume that a newly announced investigation or notification has the same legal effect as a final designation.
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The practical impact depends on whether you are a business user, developer, advertiser, publisher, or another participant using a covered service. The DMA’s “do’s” and “don’ts” are duties of designated gatekeepers, not general compliance requirements for every business.
| DMA area | Potential business significance | Limits to check |
|---|---|---|
| Access to data generated on a platform | A business user may be able to obtain data it generates through use of the core platform service, helping with analytics, customer relationships and switching decisions. | The applicable service, data category, access method and authorisation conditions are service-specific. |
| Interoperability | Third parties may be able to interoperate with a gatekeeper’s service in specified situations. This can matter to developers, messaging providers and integrators. | Technical requirements, security conditions and the particular DMA article determine what must be made interoperable. |
| Advertising information | Advertisers and publishers may receive tools and information needed for independent verification of advertising performance and pricing. | Available fields, reporting methods and technical limits differ by advertising service. |
| Promoting outside offers | A business may be able to tell customers about an offer outside the gatekeeper’s platform and conclude a contract through that outside channel. | The right is tied to the relevant service and must not be confused with a guarantee of preferred ranking, zero fees or a particular conversion rate. |
| Distribution and user choice | Rules can affect app distribution, pre-installed software, choice screens and the ability to uninstall certain software, changing customer-acquisition routes. | These are obligations on designated services; they do not make every distribution channel open on identical commercial terms. |
| Portability and messaging access | Where the relevant obligation applies, portability tools or messaging interoperability can reduce dependence on one platform. | Eligibility, consent, authentication and technical implementation remain service-specific. |
What the DMA does not promise
- It does not make every digital platform a gatekeeper.
- It does not automatically cover every product of a designated company.
- It does not guarantee that a business will win a dispute with a platform or receive a particular commercial outcome.
- It does not eliminate the need to comply with privacy, consumer-protection, intellectual-property, cybersecurity or sector-specific rules.
How can a business use its DMA rights?
The safest approach is to start with the exact service and relationship rather than a general complaint about a large technology company.
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- Identify the service. Record the precise product involved, such as an app store, marketplace, search service, advertising service, social network, browser, operating system or messaging service. Confirm its status in the Commission’s Gatekeepers Portal.
- Define your role. State whether you are a business user, developer, advertiser, publisher, end user or another intermediary. The same platform event can trigger different rights for different roles.
- Match the problem to an obligation. Decide whether the issue concerns data access, portability, interoperability, advertising verification, steering customers to an outside offer, app distribution, ranking or another DMA subject.
- Use the gatekeeper’s implementation channel. The Commission’s Business Portal provides service-specific guides, API documentation and forms for requests to gatekeepers. Follow the stated authorisation, consent and technical requirements.
- Keep an evidence file. Save relevant contracts, screenshots, error messages, API responses, dates, account identifiers, rejected requests and the financial or customer effect. A precise record is more useful than a broad allegation.
- Escalate through the Commission’s business channel. After checking the available guidance, a business can contact the DMA team about an implementation concern. This is an official first step, not a promise that the Commission will order a particular remedy.
- Obtain advice for a material dispute. For significant revenue, access or investment decisions, have qualified counsel assess the relevant DMA article alongside contract, competition, privacy and consumer law.
How to read the DMA’s different statuses
News about a platform can refer to a binding rule, a Commission decision, an ongoing dialogue or a preliminary view. Those statuses should not be treated as interchangeable.
| Status | What it means for a business | Example or action |
|---|---|---|
| Final gatekeeper designation | The provider and specified core platform service are within the DMA framework, subject to the applicable obligations and implementation dates. | Check the service entry in the Gatekeepers Portal and the gatekeeper’s implementation materials. |
| Commission non-compliance decision | The Commission has made a finding and may impose a fine or other remedy. Attribute the finding to the Commission; do not describe it as a court judgment unless separately established. | Review the decision, remedy and any stated compliance timetable. |
| Regulatory dialogue, specification or market investigation | The Commission is examining implementation or interpretation. The final obligation or outcome may still develop. | Use current Commission notices rather than relying on an early proposal. |
| Preliminary view | The Commission has announced an initial position, not a final designation or decision. | On 25 June 2026, the Commission said it preliminarily considered Amazon Web Services and Microsoft Azure candidates for gatekeeper designation for cloud computing services. Confirm the live status before treating either as definitively designated. |
What penalties can apply?
The Commission’s published framework allows fines of up to 10% of a company’s total worldwide annual turnover, rising to 20% for repeated infringements. Periodic penalty payments can reach 5% of average daily turnover. Systematic infringement can lead to proportionate additional behavioural or structural remedies.
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July 2026 Google decisions
On 23 July 2026, the Commission announced two Google non-compliance decisions. It said Google Search favoured Google’s own services over third parties and that Google Play restricted businesses from steering users to alternative purchase channels. The Commission announced fines of €460 million and €430 million, €890 million in total. These figures and findings are the Commission’s announcement; this article does not assume a later appeal outcome or court confirmation.
What did the DMA’s first review find?
The Commission’s first DMA review, required by 3 May 2026, reported early changes including consent mechanisms, portability tools, choice screens and interoperability measures. Stakeholders also raised concerns about circumvention, transparency and technical difficulties. The review did not propose changing the gatekeeper designation criteria and identified cloud computing and artificial intelligence as priorities.
For a business, that means implementation is still evolving. An option shown in one service today may be revised through technical changes, Commission proceedings or a later decision, so use the current official service documentation when planning integrations or customer-acquisition channels.
A practical DMA checklist for finance and operations teams
- List every critical platform used for sales, advertising, payments, app distribution, messaging, analytics and customer support.
- Mark which relationships could make your company a business user, developer, advertiser or publisher.
- Map revenue, customer data and costs that depend on each covered service.
- Check the live Gatekeepers Portal and the Commission’s Business Portal before relying on a designation or right.
- Ask for data, interoperability or steering access in the gatekeeper’s prescribed format and retain the response.
- Model a fallback channel in case an API, app-store route or advertising tool is unavailable or technically limited.
- Escalate a documented implementation concern to the Commission’s DMA team when the official materials do not resolve it.
Bottom line
The DMA can give businesses meaningful alternatives to a gatekeeper’s default distribution, data and advertising arrangements, but it is not a blanket right to use every platform feature on any terms. Identify the exact designated service, your role and the specific obligation, then use the Commission’s current portal and technical materials. Treat the end-of-2025 gatekeeper list, enforcement announcements and cloud proposals as status-sensitive information that must be checked for updates.
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