When the Digital Markets Act reached full enforcement, it was billed as the most consequential competition law of the digital era. Rather than litigating abuses after the fact, the DMA imposes up-front obligations on a handful of designated “gatekeepers” — the platforms so dominant that they control access to entire markets.
A year on, it is possible to judge results rather than intentions. The verdict is nuanced: the DMA has produced concrete, visible changes, but enforcement battles and creative compliance have blunted some of its intended effects. The next phase will determine whether it reshapes the market or merely irritates the incumbents.
What the DMA actually requires
The DMA targets specific behaviours that entrench dominance. Gatekeepers must allow third-party app stores and sideloading, refrain from self-preferencing their own services in rankings, let businesses contact their own customers directly, provide data portability and interoperability, and stop combining personal data across services without consent.
Crucially, the obligations apply regardless of whether harm can be proven in a given case. This shifts the burden: instead of regulators chasing abuses for years, the platforms must comply by default and justify themselves if they do not.
Non-compliance with the DMA can trigger fines of up to 10% of a company’s global annual turnover — rising to 20% for repeat offences. For the largest gatekeepers, that is tens of billions of euros.
What actually changed
Several changes are now visible to ordinary users. Alternative app stores and sideloading have appeared on mobile platforms that previously forbade them. Messaging interoperability obligations have begun to crack open walled gardens. Browser and default-app choice screens now greet users in ways that were unthinkable a few years ago, creating genuine openings for European challengers such as Qwant, Startpage and Ecosia.
Business users have gained too. The right to steer customers to cheaper off-platform options, and to access the data platforms hold about their own customers, has shifted bargaining power, particularly for smaller firms that had no leverage before.
Where it has fallen short
Compliance has often been grudging and minimal. Gatekeepers have, in several cases, implemented the letter of the law while undermining its spirit — introducing new fees, friction or design choices that discourage users from exercising their new freedoms. Choice screens can be technically compliant yet subtly steer users back to defaults.
The Commission has opened investigations into exactly these tactics, signalling that “malicious compliance” will not be tolerated. But each dispute takes time, and during that time the intended benefits are diluted. The gap between the rule on paper and the experience in practice remains the DMA’s central weakness.
The opportunity for European challengers
For European companies, the DMA is less a regulatory burden than an opening. By forcing gatekeepers to offer genuine choice, it gives smaller, privacy-respecting alternatives a fairer shot at users who were previously locked into defaults. Search engines, browsers, app stores and messaging apps all stand to benefit if they can convert newly available choice into actual adoption.
The lesson for challengers is that regulation creates the opening but does not walk through it for you. The platforms that win the choice-screen era will be those that pair the regulatory tailwind with a genuinely better, more trustworthy product.
What comes next
The DMA is a living regime. Expect the list of gatekeepers and core platform services to expand, enforcement of anti-circumvention to intensify, and the Commission to refine its interpretation through cases. The interplay with other European laws — the GDPR, the Data Act, the AI Act — will also sharpen, creating a denser web of obligations for dominant platforms.
- More designations as new services cross the gatekeeper thresholds
- Tougher action against minimal or deceptive compliance
- Clearer interoperability requirements, especially in messaging
- Closer coordination with privacy and data-portability rules
How a company becomes a gatekeeper
The DMA does not apply to every large company — only to those designated as gatekeepers, a status reserved for the platforms that genuinely control access to markets. Designation rests on a combination of thresholds: very high turnover or market value, a large user base across the EU, and control of a ‘core platform service’ such as an app store, search engine, operating system or messaging service that acts as a gateway between businesses and consumers.
Once designated, a company has a short window to bring the relevant services into compliance. The list is not static: as new services grow and as the Commission scrutinises more of the market, additional designations follow. This dynamism is deliberate — the regime is meant to keep pace with a fast-moving industry rather than freeze a single snapshot of dominance into law.
The threshold approach has the virtue of predictability but also draws sharp lines that companies inevitably probe. Expect continued argument at the boundaries over which services count as core platform services and which companies have truly crossed into gatekeeper territory.
The global ripple effect
Although the DMA is European law, its effects rarely stop at Europe’s borders. When a platform re-engineers a product to comply — opening an app store, adding interoperability, presenting a choice screen — it often finds it simpler to ship that change globally than to maintain a separate European version. Europe’s regulatory choices thus quietly become defaults for users far beyond the EU.
This ‘Brussels effect’ has played out before with the GDPR, which became a de facto global privacy benchmark. The DMA appears to be following a similar path, with regulators elsewhere studying it as a model for their own competition reforms. For European challengers, the implication is encouraging: the openings the DMA creates at home may be mirrored in markets abroad, widening the opportunity well beyond the continent.
Conclusion
One year in, the Digital Markets Act has proven it can move even the largest platforms — something competition law spent decades failing to do quickly. App stores have opened, defaults have loosened, and business users have gained real rights. That is a meaningful shift.
But the DMA’s ultimate impact depends on enforcement stamina. If the Commission pursues circumvention as aggressively as it designed the rules, the digital market could become genuinely more contestable. For European challengers, the message is simple: the door is open wider than it has ever been — now earn the users walking through it.
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