Money & markets
Regulation (EU) 2022/1925
Digital Markets Act
Digital Markets Act
A handful of giant tech firms (called gatekeepers) cannot favor their own apps, lock you in, or block rivals from talking to their users.
Does this hit me?
More choice of apps, browsers, and how you pay inside stores. Some settings screens got busier — that is the point: you, not the gatekeeper, pick defaults.
Check in the wizardPick a country in the header to see who enforces this at home. Union text is not the last word for directives.
How it rolls in
Nov 2022
Entered into force.
Sep 2023
First gatekeepers designated.
Mar 2024
Most obligations started.
Why it exists
Competition cases took years. The DMA sets do's and don'ts in advance for firms that sit at the bottleneck of search, app stores, ads, and messaging.
What actually changes
- Gatekeepers must allow sideloading and alternative app stores on their OS, with security caveats.
- Default browsers and search can be chosen more freely.
- Messaging services must work toward interoperability.
- Self-preferencing in ranking and tying of services is restricted.
How it hits you
More choice of apps, browsers, and how you pay inside stores. Some settings screens got busier — that is the point: you, not the gatekeeper, pick defaults.
For citizens
What this does to everyday life
Rights, bills, and what you can ignore. You are usually not the one who files — companies and states are.
Choice of apps and defaults
On gatekeeper phones and browsers you should be able to pick search, browser, and stores more freely. The extra screens are the point: the default is yours.
Messaging over time
Interoperability duties aim to let you message across some big services without living inside one garden. This lands in stages and will feel uneven at first.
Rights you actually get
- To uninstall pre-installed apps (with security caveats).
- To choose defaults for search and browser on designated systems.
Costs and trade-offs
- More choice screens. Security warnings when sideloading are allowed and useful — they are not a ban.
What you can do
- Change default browser and search. If a gatekeeper blocks a rival app without a real security reason, that is a competition issue.
What you can ignore
- You do not file DMA paperwork. Almost nobody is a gatekeeper except a handful of global firms.
If something goes wrong
National consumer bodies for everyday issues; the European Commission enforces the DMA against gatekeepers.
More citizen notes across files: For people
Heard this? Not quite.
Claim: This breaks your phone's security.
Sideloading is allowed, not forced. Gatekeepers can keep proportionate security measures; they cannot use security as a blanket lock-in.
Latest official statements
All EU NewsNo tagged Commission, Parliament or Council statement in the current feeds.
Board one-pager
Board one-pager
Who this is for: EU finance, trade and reporting teams. Regulation (EU) 2022/1925. Gatekeeper duties since March 2024.
Scope
- You have been designated a gatekeeper by the Commission — a short, public list.
First 90 days
- If designated: Run a gap assessment against Articles 5–7 (tying, data use, interoperability, sideloading).
- If not designated: Document how gatekeeper rules help your distribution or ads access; keep evidence for complaints.
Penalties: Up to 10% of worldwide turnover (20% for repeat) for gatekeepers. Periodic penalty payments possible.
For companies
How to stay on the right side of this file
Practical order of work, not a substitute for counsel. Only designated gatekeepers. Most companies are beneficiaries, not addressees.
You are probably
Only designated gatekeepers. Most companies are beneficiaries, not addressees.
Effort
A scoped programme this year beats a scramble at the apply-date.
Budget
SME: owner time plus one honest vendor. Large: a named lead, not a taskforce slide.
Roles in this file
The same company can wear more than one hat. Classify before you buy a tool.
Regulatory affairs
This pack names Regulatory affairs as an owner of early work.
Run a gap assessment against Articles 5–7 (tying, data use, interoperability, sideloading).
Commercial + legal
This pack names Commercial + legal as an owner of early work.
Document how gatekeeper rules help your distribution or ads access; keep evidence for complaints.
Are you in scope?
Watch- You have been designated a gatekeeper by the Commission — a short, public list.
Usually not, if
- Almost every SME and most large firms that are not core platform services at Union scale.
First moves
- If designatedRun a gap assessment against Articles 5–7 (tying, data use, interoperability, sideloading).Regulatory affairs
- If not designatedDocument how gatekeeper rules help your distribution or ads access; keep evidence for complaints.Commercial + legal
- You do not file DMA reports. Use the law as leverage in app-store and ads negotiations.
If you skip this
- Spending a legal budget on DMA if you are not on the list.
Done looks like
- Designation decision (if any).
- Compliance reports if you are a gatekeeper.
Keep this evidence
- Designation decision (if any).
- Compliance reports if you are a gatekeeper.
Ask vendors
- Are you a designated gatekeeper for this service?
Where programmes usually break
- Spending a legal budget on DMA if you are not on the list.
Call counsel when
- Up to 10% of worldwide turnover (20% for repeat) for gatekeepers. Periodic penalty payments possible.
- A supervisor letter, a dawn information request, or a deal that warrants this file.
Enforcement
Up to 10% of worldwide turnover (20% for repeat) for gatekeepers. Periodic penalty payments possible.
European Commission (direct enforcement).
Need a stack, not one file? Open the company desk
Professional briefing
Legal architecture and duties
For counsel, compliance, and policy teams. Not advice. The Official Journal still wins.
- Instrument
- Regulation
- Legal basis
- Art 114 TFEU · Regulation (EU) 2022/1925
- Application
- In force November 2022; obligations for designated gatekeepers from 6 March 2024 (six months after designation).
Ex-ante competition law for a closed list of ‘core platform services’ provided by designated gatekeepers. Almost no company is a gatekeeper; almost every software, ads, and app-distribution strategy is affected by how those few behave. The Commission has exclusive enforcement. Fines up to 10% of worldwide turnover (20% for repeat).
How the file is built
Designation (Art 3)
Quantitative presumptions (turnover, market cap, user numbers) plus a qualitative escape. Designation is by Commission decision, per core platform service.
Do’s and don’ts (Arts 5–7)
Self-preferencing, tying, data combination, steering, interoperability of number-independent interpersonal communications, sideloading, uninstall of pre-installed apps.
Antitrust overlay
Arts 101–102 TFEU remain. DMA is faster and more categorical; it is not a safe harbour from antitrust.
Operators
| Role | Who | Core duties |
|---|---|---|
| Gatekeeper | Designated undertaking for specified core platform services. | Compliance with Arts 5–7, reporting, interoperability specifications, audit of consumer-profiling techniques. |
| Business user / rival | Depends on the CPS (advertisers, app developers, merchants). | No DMA filing; use the Commission complaints channel and national courts for follow-on. |
Scope
Core platform services provided to business users established in the Union or end users established or located in the Union, irrespective of the gatekeeper’s place of establishment.
In
- Closed list of core platform services: e.g. marketplaces, app stores, search, social, video-sharing, OSs, browsers, virtual assistants, cloud, advertising services.
- Only designated gatekeepers, for the designated CPS.
Out, or narrower than assumed
- Non-designated large platforms (they may still be VLOPs under the DSA).
- SMEs as addressees of the do’s and don’ts — they are beneficiaries, not duty-holders.
Operative provisions
| Anchor | Rule | What it does in practice |
|---|---|---|
| Art 5(2) | No combining personal data across CPS without GDPR-grade consent. | Login walls that force data combination are a DMA + GDPR problem. |
| Art 6(5) | No self-preferencing in ranking. | The remedy is access and ranking principles, not a break-up by default. |
| Art 7 | Interoperability for specified messaging functions, staged. | Security caveats are allowed; total lock-in is not. |
| Art 30–31 | Fines 10%/20%; periodic penalties; possible structural remedies after systematic non-compliance. | Board-level DMA compliance function at designated firms. |
Secondary law and guidance
- Commission implementing regulation on cooperation and detailed designation process.
- Gatekeeper compliance reports (public versions).
National layer. Commission exclusive for DMA infringements. National competition authorities may assist and still run 101/102 cases.
How it sits with other files
Different tests and remedies. A firm can be a VLOP, a gatekeeper, both, or neither.
DMA consent for data combination does not relax purpose limitation or children’s rules.
Cloud switching and product-data access sit next to DMA cloud/OS obligations — map which statute actually binds you.
Enforcement and private rights
Who
European Commission (DG COMP / DMA team).
Tools
Investigations, interim measures, 10/20% fines, behavioural and, in last resort, structural remedies.
Private rights
Damages in national courts; DMA infringements can support follow-on claims.
Risk register
| Risk | Signal | Control |
|---|---|---|
| Assuming you are a gatekeeper | SME app store compliance programme cloned from DMA Art 6 | Read Art 3; if not designated, park DMA as a vendor-watch item. |
| Steering bans in IAP systems | Contract clauses that block out-of-app offers | For designated CPS, rewrite developer terms; others watch the case law. |
Open issues
- How far interoperability can be required without compromising encryption.
- Treatment of AI assistants as a CPS.
- Interaction of sideloading security warnings with effective user choice.
Primary sources
A handful of giant tech firms (called gatekeepers) cannot favor their own apps, lock you in, or block rivals from talking to their users.
You feel it now
The on-switch is still coming — do not wait for the headline.
Next
Gatekeeper duties since March 2024
Where it lands
| Channel | People | Companies |
|---|---|---|
| App distribution and defaults | More choice of apps, browsers, and how you pay inside stores. Some settings screens got busier — that is the point: you, not the gatekeeper, pick defaults. | Choice screens, sideloading, and alternative stores change how you reach users on gatekeeper OS — if you are an app maker, this is opportunity more than a new filing. |
| Ranking and self-preferencing | More choice of apps, browsers, and how you pay inside stores. Some settings screens got busier — that is the point: you, not the gatekeeper, pick defaults. | If you compete with a gatekeeper's own service, you have a clearer complaint path when ranking looks rigged. |
Who gains
Users and business users who depend on those platforms.
Who pays
Designated gatekeepers (a short list of global platforms).
Who pays
Designated gatekeepers (a short list of global platforms).
Who benefits
Users and business users who depend on those platforms.
Read the official text