DMA Review

The first review of the DMA finds that the regulation is already delivering positive results in making digital markets fairer and more contestable, despite being in its early stages of implementation. For example, the DMA has driven significant changes in gatekeepers’ behaviour, including new consent mechanisms, data portability tools, choice screens, and interoperability measures. These adjustments are opening opportunities for smaller businesses and giving users more control over their digital experiences.

However, the DMA has not yet achieved its full potential. Some stakeholders emphasised the need for stronger enforcement and greater transparency, citing concerns such as gatekeepers deploying measures to sidestep their obligations and persistent technical difficulties – for example, when attempting to interoperate with gatekeepers’ services - that hinder the ability to benefit from DMA solutions.

The review concludes that it is too early for legislative changes, as the full impact of many obligations will take more time to become apparent.

Instead, the focus will remain on effective enforcement, regulatory dialogue, and raising awareness particularly among start-ups, SMEs, and consumers, to ensure they can benefit from the DMA’s new opportunities. The Commission will also explore targeted procedural improvements, such as simplifying compliance processes and increasing transparency.

Finally, the review highlights how DMA is designed to be future-proof and adapt to emerging challenges, including with respect to cloud computing and AI services, where the Commission has already taken action. The Commission will continue monitoring market developments and assessing whether further adjustments are required in future reviews.

The DMA is already empowering end users in meaningful ways, with specific benefits becoming increasingly visible. Examples of these benefits include: 

• End users have more choice via the choice screens for browser and search engines and the ability to un-install default apps;
• Users also have greater control over how their personal data are used by gatekeepers. Gatekeepers must seek end users’ consent before combining or cross-using their personal data across gatekeepers’ services, giving users control and preventing unsolicited profiling. Switching between services is also easier thanks to data portability and sharing;
• End users can now easily port their data outside of gatekeepers’ ecosystems - including data from social media posts and likes on Facebook, Instagram and TikTok, their search history on Google Search, and purchase history on Amazon;
• Alphabet no longer forces users of Android, YouTube and Google Play to subscribe to the Gmail service as a condition to accessing these services;
• End users can now transfer eSIMs between iPhones and Android phones. Google and Apple have also advanced their work to facilitate switching from iOS to Android devices and vice-versa, and between browsers;
• Hotels and car rentals can now set their own prices and conditions on their own platforms and are no longer restricted from offering better deals outside platforms such as Booking.com - resulting in lower prices and better conditions for end users.

Overall, thanks to the DMA, users benefit from increased competition translating into better services, potential price reductions, and improved privacy. They also gain indirect benefits from a more innovative ecosystem where both EU and global players can compete more freely.

Early indicators, like engagement with choice screens and high refusal rates for data sharing and combination across gatekeeper services, suggest users are actively exercising these new rights. 

That said, these gains may come with some small frictions. For example, users might see changes in how services work, with less seamless integration. They may also need to make choices, where before the gatekeeper did not offer any. While these changes may be noticeable at first, they are necessary to empower users with real choice and reduce structural dependencies. This will help create more competitive and innovative digital markets. Over time, as users get used to these new options, any inconveniences should decrease.

The DMA is already making digital markets fairer by curbing the advantages of established gatekeepers and opening up previously closed ecosystems. 

SMEs and other businesses are already beginning to see tangible benefits from the DMA, particularly through improved access to data, fairer contractual conditions, and new channels to reach customers outside gatekeeper-controlled environments. These changes reduce dependency on gatekeeping platforms and better enable businesses to compete on the merits of their products and services. 

For example:

• Alternative browsers and search engines, including Aloha, Ecosia, Qwant and DuckDuckGo, have seen increased uptake following the introduction of choice screens, with some providers reporting significant user growth in key markets such as France and Germany;
• Alternative app stores, such as Aptoide, the Epic Games Store and AltStore have launched on Apple’s operating systems – previously closed to third-party app stores - and are continuously expanding their offers;
• App developers can now distribute their apps from their own websites on iOS and iPadOS;
• Around 40 third-party developers, many of them SMEs, like DataPods, Gener8, Hoda, Smart Data Donation Service and Fabric, have successfully integrated with gatekeepers’ APIs to port user data and develop innovative services, such as tools that allow users to aggregate, manage and share their personal data across platforms;
• Messaging interoperability has enabled new providers to emerge, including Fyello Productivity, who provides BirdyChat, one of the first services to interoperate with WhatsApp;
• App developers can now request interoperability with Apple’s operating systems, enabling third-party apps to perform functions that were previously available solely to Apple’s own apps, such as activating alarms or sending emergency SMSs even when the phone is off.

At the same time, fairness has improved through more transparent advertising conditions. Advertisers and publishers now have access to pricing, fees, remuneration, and performance data for advertisements, bringing much-needed transparency to an area previously considered a "black box". The DMA has also imposed restrictions on exploitative data use and clearer rules for platform–business interactions. Respondents to the public consultation report increased uptake of non-gatekeeper services and more neutral user interfaces, although concerns remain around slow or formalistic compliance.

Through harmonised obligations on global gatekeepers, the DMA enables both EU-based and non-EU-based firms to access more contestable digital ecosystems when operating in the European market. This matters especially for innovative start-ups and scale-ups seeking to enter or expand within the EU without facing structural barriers. 

Following its in-depth review, the Commission is not proposing to revise the DMA. The evaluation finds that the regulation remains fit for purpose and does not require major legislative amendment at this stage. After only just over two years of enforcement, the DMA has already delivered concrete positive results, such as greater contestability, fairer market conditions, and new opportunities for businesses and consumers.

Given the relatively short period since the DMA’s obligations came into effect, its full potential has yet to be realised. Businesses and users have only recently begun to take advantage of the opportunities created by the regulation, and more time is needed to assess its long-term impact. It seems therefore too early for a major revision of the regulation. The Commission will continue to monitor developments closely and gather the necessary data to determine whether any modifications may be required in the future.

In the meantime, the Commission has already started to address emerging issues raised during the public consultation. The Commission is considering targeted changes, making use of the DMA’s flexibility tools to keep the regulation future-proof. This includes an assessment of cloud services, where investigations into potential gatekeeper designations are underway, alongside assessments of whether changes to existing obligations are required to tackle competitive concerns in these areas. This also includes monitoring the evolution of AI services, where enforcement is already underway, including with two specifications proceedings on interoperability of AI services and the sharing of online search data.

As part of this monitoring, the Commission will assess whether any targeted modification of the DMA is needed to address the practices and challenges to contestability and fairness that are emerging or will emerge in AI services.

After careful consideration of the feedback submitted by stakeholders, the Commission considers that the existing framework under the DMA for designating gatekeepers remains fit for purpose.

Therefore, the criteria for designation, based on the dichotomy of quantitative and qualitative designation, with appropriate and evidence-based threshold values and criteria for assessment, will not be amended.

The review process identified some areas for improvement.

In particular, it highlighted cloud services and AI as critical priorities to ensure fair and contestable digital markets. The Commission has already undertaken concrete actions in this regard. In November 2025, it launched three market investigations into cloud computing services. Two of these assess whether Microsoft and Amazon should be designated as gatekeepers for their respective cloud computing services, Amazon Web Services and Microsoft Azure while the third examines whether the DMA can effectively address practices that may limit competitiveness and fairness in cloud computing. Regarding AI services, the Commission has focused regulatory dialogues on enabling easy changes to default settings and on ensuring AI services have equal access to operating systems. In January 2026, two specification proceedings were opened in relation to Alphabet, which also address AI-related concerns, such as on interoperability and access to search data. These areas will remain a key focus. 

The Commission is also taking concrete actions to promote transparency and provide enforcement guidance, as requested by stakeholders. For example, in collaboration with the European Data Protection Board (EDPB), it is developing Joint Guidelines on the interplay between the DMA and the GDPR. These guidelines aim to help gatekeepers  comply with the two sets of rules, improving legal certainty for businesses in the EU. Moreover, the Commission will continue to use its power to specify how gatekeepers should comply with DMA obligations in order to assist their effective compliance. The Commission will also remain committed to organising stakeholder workshops yearly and, based on the stakeholder feedback, to improving their quality. 

Another area where the Commission is taking concrete actions concerns the review of the DMA’s procedural framework. The Commission will explore whether potential targeted modifications to the framework are needed, based on the learnings of the first two years of enforcement. It will also consider possible adjustments to gatekeepers’ compliance templates to simplify and streamline reporting.

The Commission identified five key themes related to AI services:

1. Interoperability – e.g. equal access of AI-based services to operating systems.
2. Self-preferencing – more favourable treatment of gatekeepers’ own AI services.
3. Access to data – in particular, as critical input for the development of alternative AI services.
4. Cloud dependencies – in particular, access to cloud computing services for the training and deployment of AI models and services.
5. Strengthened cooperation to maximise synergies between regulatory tools – including the importance of cross-regulatory cooperation for ensuring consistent enforcement.

The Commission based its findings on a dedicated consultation on AI, on the mapping of the regulatory interplay carried out by the DMA High-Level Group, and on the Commission’s regulatory dialogues with gatekeepers. With respect to regulatory interplay, it is important to recall that the DMA cannot be seen in isolation, and that other laws, such as the AI Act and competition law, also aim to address issues identified across the AI value chain.

The Commission has already begun to address some of the identified issues under the DMA. For instance, the Commission opened two specification proceedings to assist Alphabet in meeting its obligations relating to interoperability and online search data sharing in the context of AI services. 

The Commission will assess what can be learned from these ongoing AI-related investigations to determine whether additional interventions are needed to address concerns raised in the public consultation. In the meantime, the Commission is already applying relevant DMA obligations to AI services.

Regarding possible designations, the question often turns on whether AI technologies or services are either an integral part of designated core platform services – and thus already covered – or whether they are a distinct service potentially warranting designation. As regards the latter, the Commission will assess in particular whether certain AI services should potentially be designated as virtual assistants core platform service. 

Given the importance of cloud services for Europe’s digital economy, cloud services were a major area of focus in the feedback received in the DMA review consultation.

A broad group of stakeholders saw the need to designate gatekeepers for cloud computing services. Such a designation of the major providers of cloud services was considered beneficial for the competitive dynamics of cloud services, with particular importance for interoperability, data portability, and to train and deploy AI models and services. In order to address these competitive dynamics in such an important sector, several respondents also called for an expansion of certain DMA obligations to cloud services.

Against this backdrop, the Commission opened three market investigations on cloud computing services in November 2025. Two market investigations are examining whether Amazon and Microsoft should be designated as gatekeepers for their cloud computing services, Amazon Web Services and Microsoft Azure, respectively. The third market investigation is examining if the DMA can effectively tackle practices that may limit competitiveness and fairness in the cloud computing sector in the EU. 

The DMA review was conducted with the broader simplification agenda in mind.

In addition to assessing the criteria for the review listed in the regulation, notably the DMA’s impact on fairness and contestability in the digital sector, the Commission also considered possible areas of simplification and burden reduction in the DMA.

This simplification potential was explored not just for businesses and end users looking to make use of their new rights under the DMA, but also in relation to gatekeepers’ compliance efforts. 

The Commission will keep working with gatekeepers and other parties to find the most effective ways to simplify regulatory processes and ensure proper compliance, including with the use of templates for reporting and guidance for compliance. The Commission will also monitor whether services should no longer be considered gatekeepers if they no longer meet the criteria.