Executive Summary

Adopted in 2022, the Digital Markets Act (DMA) imposes obligations on large online platforms to ensure contestable and fair digital markets. The Commission is consulting stakeholders ahead of its first review report, due by 26 May 2026. This submission provides a factual overview, critical analysis, and policy recommendations to the Commission across the designation process, compliance phase, and cooperation frameworks as of July 2025.

The designation process has operated as intended. However, concerns have been raised about an imbalance between designated U.S. platforms and similarly sized European and Chinese firms, recommending the latter to be designated to level the playing field. While calls to expand the DMA to cover cloud and GenAI services are growing, the Commission should first monitor these dynamic and nascent markets before extending the scope.

Compliance is still in its early stages of development. While merger reporting functions well, no cases have been referred under the European Merger Regulation (EUMR), and the Commission should assess the reasons before revising its merger policy. Compliance and consumer profiling reports offer limited value to stakeholders and should be made more accessible to them. The Commission should also structure the informal dialogue process, prioritise cooperative resolution, clarify its use of specification decisions over non-compliance investigations, issue guidance on key obligations, and monitor GenAI developments to ensure the DMA remains fit for purpose before changing obligations.

Existing cooperation mechanisms and forums have supported consistent enforcement, but can be strengthened. The Commission should deepen its collaboration with national competent authorities, particularly national competition authorities (NCAs), through practical frameworks, increased transparency, and enhanced stakeholder engagement dynamic and nascent markets.