The Digital Markets Act, early enforcement results and challenges ahead

On 4 March 2026, the EUI Centre for a Digital Society hosted an online policy debate examining the Digital Markets Act’s (DMA) first two years in action. The discussion took stock of the DMA’s impact on fairness and contestability in digital markets and explored the enforcement hurdles that lie ahead.

The event was timed to feed into the European Commission’s forthcoming evaluation of the DMA, expected by May 2026. Speakers focused in particular on how the EU Regulation is shaping interoperability between gatekeepers’ hardware/software and the services offered by third-party app developers and device manufacturers. A second key theme was the growing influence of Generative AI on competitive dynamics in digital markets — and the question of whether the DMA is equipped to respond to the rapid market shifts Gen AI brings.
The roundtable brought together senior representatives from the European Commission, major digital platforms, civil society organisations and academia. The CDS team was represented by Marco Botta, J. Scott Marcus and Maria Alessandra Rossi, with concluding remarks delivered by Pier Luigi Parcu.

Interoperability: why it is important in digital markets and what the DMA has achieved so far

Interoperability is one of the few DMA tools that can, at least in principle, reshape the structure of competition rather than simply constrain conduct. In digital markets with strong network effects, high switching costs and ecosystem lock-in, competition often takes the form of ‘competition for the market’: once an ecosystem becomes entrenched, rivals struggle to compete within it. Interoperability can alter this logic. By enabling cross-service connectivity (horizontal interoperability, under Article 7) and access to operating-system and hardware features on parity terms (vertical interoperability, under Article 6.7), the DMA can lower entry barriers, reduce dependence on a single ecosystem and make competition in the market more viable.

One of the clearest points to emerge from the roundtable was that interoperability matters for consumers, even if the term itself is not part of everyday language. Once translated into practical examples, however, its significance becomes immediately understandable. Consumers may not speak of “horizontal” and “vertical” interoperability, but they do understand the value of being able to communicate across services, to use third-party devices more easily within mobile ecosystems, or to access apps and functionalities without being pushed towards a gatekeeper’s own services. Framed in this way, interoperability is not just a technical matter: it affects consumers’ choice, convenience and the real possibility of switching between different service providers.

 ‘Interoperability is where the DMA moves from constraining gatekeepers’ conduct to opening digital markets to competition’

A second message was that there is already some early indication that the DMA’s interoperability measures are beginning to have effects, even though it is probably too soon to observe fully fledged market outcomes. The discussion referred in particular to early signs of entry and experimentation by third-party firms in areas where gatekeeper control had previously made expansion more difficult. The point was not that long-run effects can already be measured with confidence. Rather, these first responses are meaningful insofar as they point to the fact that some barriers are starting to loosen. At the same time, the speakers agreed that effective interoperability cannot be assessed merely by checking whether an interface formally exists. Access must also be workable in practice: stable, usable, sufficiently documented and not weakened by procedural friction, degraded quality or unilateral interface changes.

The discussion also made clear that interoperability is not a binary concept. It comes in different forms and degrees, and these differences shape the trade-offs it entails. The introductory presentation emphasised several relevant dimensions, including technical interfaces, feature access, data and identity management, security, governance conditions and user experience. This broader framing mattered for the discussion because the depth of interoperability affects both its benefits and its risks. In particular, an important distinction emerged between interoperability at the superficial technological layers and that which reaches core elements of the technology stack. This distinction is especially important for security aspects. Where access concerns limit functionality, the associated risks may be more manageable. By contrast, where interoperability reaches deeper layers, such as operating-system hooks, privileged entitlements, or authentication mechanisms, the implications for security and system integrity become more serious. The roundtable, therefore, did not frame the issue as a simple choice between openness and security. The more nuanced view was that different interoperability choices raise different security challenges, and that these need to be addressed through correspondingly granular governance tools.

This is also why specification proceedings emerged as a key procedural mechanism in the DMA architecture. Their role is to translate broad legal obligations into workable implementation choices. The discussion highlighted that interoperability is rarely “plug-and-play”: effective access depends on decisions about scope, timing, documentation, quality standards, testing, dispute resolution, and adaptation over time. In that sense, specification proceedings are essential to ensure that compliance is not merely formal but can support effective market access.

Finally, the webinar highlighted a real tension around timing. On the one hand, in digital markets, delay can preserve lock-in and reduce the practical effects of regulation. On the other hand, rushed implementation may come at a cost, especially when deeper, more complex forms of interoperability are involved. In these cases, accelerated procedures may not leave enough time to fully understand the trade-offs at stake, particularly those involving security, product integrity, and the evolution of interfaces over time. The broader lesson from the discussion was therefore that interoperability under the DMA should be seen not as a one-off compliance exercise, but as an ongoing governance process. Its success will depend not only on the existence of legal obligations, but on the quality, timing and adaptability of the procedures through which those obligations are specified and enforced.

Gen AI: reshaping the DMA boundaries

Since the launch of ChatGPT in November 2022, Gen. AI has rapidly reshaped digital markets. BigTechs have rushed to embed AI features into their services (e.g., search engines, social networks, virtual assistants), promising more personalised services and, in turn, greater value for consumers. At the same time, a wave of new products entered the market: upstream, new large language models (LLMs) offered developers unprecedented capabilities; downstream, consumer-facing apps emerged that can generate text, images, audio or short videos from a simple prompt. From a competition-policy perspective, the first phase of the GenAI boom had some pro-competitive effects: it triggered the release of entirely new products, significantly improved the quality of existing digital services, and opened the door to new entrants—including fast-growing players such as Mistral and Anthropic. Together, these trends strengthened the overall contestability of digital markets. Yet the GenAI revolution is also exposing structural weaknesses in the value chain. Training frontier LLMs requires extraordinary capital expenditure, specialised hardware and access to vast, constantly updated datasets. Few firms possess the resources to compete at this scale. Cloud infrastructure adds a second layer of market concentration: access to hyperscalers is now essential for running and distributing LLM-powered services. Today, Amazon AWS, Google Cloud and Microsoft Azure together control more than 60% of the global cloud market—an essential bottleneck for developers and end-users alike.

 ‘The DMA entered into force on 1st November 2022. OpenAI released the first version of ChatGPT less than one month later. Question: is the DMA fit for the GenAI revolution?’

 

Against this backdrop, the Digital Markets Act stands out for what it does not say: the legislation does not contain the word “AI.” Some of the speakers at the roundtable noticed that this appears anachronistic, given the speed at which GenAI is transforming competition in digital markets. Other panellists, on the other hand, pointed out that the DMA is flexible enough to address structural competition concerns stemming from the AI transition.

A further point of discussion during the roundtable was whether and to what extent the DMA’s list of Core Platform Services (CPS) is outdated in light of AI-specific considerations. In this regard, some speakers noticed that the list of CPS should explicitly include AI-related activities, such as LLM development. They also contended that the current quantitative thresholds for gatekeeper designation fail to capture market power in critical segments such as cloud computing, where no provider has yet been designated as gatekeeper. By contrast, other speakers warned that expanding CPS categories or lowering designation thresholds would constitute regulatory overreach, imposing unnecessary burdens and potentially slowing innovation in a rapidly evolving sector.

Similar positions emerged regarding the DMA obligations. Some panellists emphasised that interoperability and data-access obligations are essential for enabling companies to develop new AI-powered services. They claimed the Commission should adopt a firmer enforcement stance to ensure these obligations are meaningful in practice. Others, on the other hand, warned that expanded data-sharing or interoperability could jeopardise the safety and privacy of AI systems while weakening incentives to innovate.

These opposing views will heavily shape the Commission’s upcoming evaluation report. Its conclusions will guide both the Council and Parliament in determining whether, and eventually how, the DMA could be revised to remain fit for the AI era. Potential reforms could include new CPS categories, updated designation thresholds or additional obligations tailored to the unique challenges posed by Generative AI.

Find out more about CDS work on this topic

Research: the online roundtable contributes to the CDS research project on Antitrust and Regulation of Digital Platforms. In particular, the CDS team has recently published a new EUI working paper titled ‘Economics by design: sequencing expertise in the Digital Markets Act’. The paper analyses the role of economics in the design, enforcement and ongoing evaluation of the Digital Markets Act.

Executive education: the online roundtable kicked off the 2026 edition of the course Regulating Digital Platforms. The course explores platform business models and the main competitive problems that have triggered a shift from antitrust to competition policy enforcement in recent years, and it compares the legislative solutions adopted in Europe and the rest of the world.

Recent developments in the DMA enforcement will also be discussed at the Florence Competition Autumn School. The 2026 edition of the training program will take place at the EUI campus in Florence on 19-22 October.