The EU Digital Markets Act (DMA) — Regulation EU 2022/1925 — entered into force on 1 November 2022 and became fully applicable in May 2023. It targets the largest digital platforms, defined as "gatekeepers," and imposes obligations designed to make European digital markets fairer and more contestable. The gatekeepers affected — Google, Apple, Meta, Amazon, Microsoft, and ByteDance — are the infrastructure on which most European businesses depend for customer acquisition, distribution, and digital commerce. The DMA does not just regulate Big Tech. It changes the commercial environment in which every business operating in or selling to the European market operates.
WHAT THE DMA ACTUALLY REQUIRES
The DMA identifies platforms as gatekeepers based on three criteria: a durable market position, a significant impact on the internal market, and a function as an important gateway for business users to reach end users. Designated gatekeepers face a set of specific obligations, including:
They must allow business users to access the data generated through their platform. They cannot rank their own products or services more favourably than competing ones. They must allow end users to uninstall pre-installed software. They cannot use data obtained from business users to compete against those same users. They must allow third-party app stores and payment systems on their platforms.
Non-compliance fines reach 10% of worldwide turnover — a figure that, for the platforms affected, represents tens of billions of euros. Systematic infringement can trigger fines of 20% of worldwide turnover.
In April 2025, the European Commission found Apple in breach of certain DMA obligations and imposed a fine. Apple has disputed aspects and indicated it would appeal. The enforcement is live and active — this is not theoretical compliance risk.
THE UK PARALLEL: THE DMCC ACT
The UK's Digital Markets, Competition and Consumers Act 2024 (DMCC) received Royal Assent in May 2024 and establishes a parallel framework for regulating digital market competition in the UK. Administered by the Competition and Markets Authority, it designates firms with "Strategic Market Status" and imposes conduct requirements and pro-competition interventions. The UK framework diverges from the EU's in some specific applications but shares the same fundamental intent: to reduce the ability of dominant digital platforms to leverage their market position in ways that disadvantage competitors and business users.
For any business operating in both the EU and UK — or planning to — the practical effect is a dual regulatory framework for digital market conduct.
WHAT THIS MEANS FOR NON-GATEKEEPER BUSINESSES
The DMA's primary targets are the gatekeepers. But its commercial implications extend significantly beyond them, affecting any business that relies on those platforms for distribution, customer acquisition, or commercial infrastructure.
For businesses that sell through Amazon Marketplace, the DMA's prohibition on gatekeepers using third-party seller data to compete against those sellers is directly protective. Amazon is prohibited from using aggregated seller data — sales volumes, pricing strategies, product performance — to develop competing private-label products. This does not eliminate the competitive tension, but it changes the legal framework within which that tension operates.
For businesses that depend on Google Search for customer acquisition, the DMA's self-preferencing prohibition — Google cannot rank its own services more favourably than competitors — theoretically changes the playing field for comparison services, travel platforms, and any business competing against Google's own products in search results.
For businesses that distribute software or content through the Apple App Store or Google Play, the DMA's obligation to allow third-party app stores and payment systems creates new distribution options and potentially reduces the commission structures that have historically extracted 15-30% of digital revenues.
The common thread is that businesses that have been commercially disadvantaged by gatekeeper self-preferencing now have a regulatory framework that nominally protects their interests — and a regulator with the enforcement tools to act.
WHAT CHANGES IN PRACTICE: THE HONEST ASSESSMENT
Regulation rarely delivers its full theoretical intent immediately. The DMA is being actively litigated by the platforms it targets. Implementation is uneven. Enforcement is complex. And the platforms have significant resources to challenge, delay, and partially comply.
The realistic assessment is that the DMA will shift the digital competitive landscape materially but gradually. The businesses that benefit most will be those that actively monitor DMA enforcement actions, understand their specific rights under the regulation, and adapt their commercial strategies to the changing platform environment — rather than passively assuming that regulatory protection will manifest without active engagement.
STRATEGIC TAKEAWAYS
- Map your dependency on gatekeeper platforms explicitly. Identify how much of your revenue, customer acquisition, or distribution runs through designated DMA gatekeepers. This is your regulatory exposure map — and your opportunity map as the DMA creates new obligations on those platforms.
- Monitor DMA enforcement actions as a live commercial signal. Every enforcement action against a gatekeeper changes the commercial environment for businesses that compete with or depend on that gatekeeper. Treat enforcement news as strategic intelligence, not regulatory background noise.
- Explore the new distribution options the DMA creates. If you distribute software or digital content through Apple or Google platforms, the DMA's third-party app store requirements create distribution alternatives that did not previously exist. Evaluate them before your competitors do.
- Build dual EU-UK regulatory compliance into your digital strategy. For businesses operating across both markets, the DMA and DMCC create overlapping but non-identical obligations and opportunities. A single compliance approach that addresses both will be more efficient than managing them separately.
- Do not assume gatekeeper compliance. The platforms are actively contesting DMA obligations. Monitor their actual behaviour rather than their stated compliance positions, and be prepared to use the regulatory complaint mechanisms if your interests are being materially affected.