EU's Digital Markets Act has "not yet reached its full potential"

• The EU's DMA review confirmed alternative app stores are now live on previously locked-down operating systems.
• Device makers secured expanded interoperability access with major OS platforms under the two-year-old regulation.
• The review drew on contributions from over 450 parties, including developers and SMEs.

The European Commission's first review of the Digital Markets Act has found the regulation "fit for purpose" after two years, but it has room to improve.

The review, which draws on input from more than 450 contributors including developers, civil society groups and academics, acknowledged that the law has not yet delivered its full impact and that gatekeepers remain resistant in key areas.

The commission claimed the DMA "has not yet reached its full potential" and that, where needed, it will "rigorously enforce the DMA" to make Europe’s digital markets fairer and more contestable. 

On accountability and advertising, the review noted that advertisers and publishers can now access pricing, fees and performance data that gatekeepers previously kept to themselves.

Operating systems have also opened up to third-party app stores, allowing new storefronts to launch and compete with dominant platforms. Mobile users are increasingly able to choose alternative browsers and search engines as defaults, and can remove pre-installed apps they don't want.

Gatekeepers are now required to publish public reports on how they comply with DMA obligations, their intended mergers and acquisitions, and the consumer profiling techniques they use.

Compliance costs and friction issues

The commission further acknowledged that complying with the DMA generates costs for gatekeepers, with some arguing the regulation should be abolished or substantially changed. 

However, it pushed back on that position, noting the costs were factored into the original legislative proposal and do not fall on SMEs or start-ups.

Some adaptation costs for end users are also unavoidable, but the commission suggested friction in users’ online experience is likely to be temporary or necessary. The commission warned that excessive friction in user interfaces could be a deliberate strategy by gatekeepers, and it will monitor this using behavioural evidence.

Seven non-compliance proceedings have been initiated to date, with Apple and Meta both found in breach and fined. Four investigations remain ongoing.

Furthermore, the commission said cloud services and artificial intelligence will be the key enforcement focus areas going forward, with three market investigations into cloud computing already opened in November 2025. 

The review concluded that while tangible progress has been made, the DMA has not yet reached its full potential, and achieving it will require continued regulatory dialogue and enforcement.