DMA Enforcement Moves from Compliance Measures to Market Outcomes.

The European Commission's latest annual report on the implementation of the Digital Markets Act (DMA) marks a transition in the regulation's development. The significance of the 2025 reporting cycle lies less in the volume of enforcement activity than in the Commission's evolving conception of compliance.

The initial phase of DMA implementation focused on designation decisions, compliance reports and the establishment of supervisory processes. Developments during 2025 indicate a growing emphasis on whether compliance measures produce observable changes in market conditions.

This shift is visible across enforcement decisions, interoperability proceedings, market investigations and regulatory cooperation initiatives.

Compliance Is Increasingly Being Assessed Through Effects

The April 2025 non-compliance decisions against Meta and Apple illustrate the direction of travel.

While the cases concerned different provisions of the DMA, both decisions focused on the practical consequences of gatekeeper conduct rather than the formal existence of compliance mechanisms. Meta was fined in relation to its advertising consent model, while Apple was found non-compliant with obligations concerning developers' ability to steer users towards offers outside the App Store.

The underlying question was not whether alternative options formally existed, but whether those options were capable of functioning as meaningful alternatives.

This distinction may prove significant for future enforcement. The reporting cycle indicates that compliance assessments are increasingly focused on whether implemented measures alter user behaviour, reduce dependency on gatekeeper ecosystems and improve market access for third parties.

Interoperability Is Emerging as a Primary Enforcement Tool

Interoperability occupied a central position in the Commission's activities throughout 2025.

The adoption of the first specification decisions under the DMA established detailed requirements concerning interoperability between Apple's operating systems and third-party devices and services. At the same time, implementation continued in relation to interoperability obligations for messaging services, with third-party providers beginning to connect to WhatsApp under the framework established by Article 7 DMA.

These developments indicate that interoperability is becoming more than a standalone obligation. It is increasingly being treated as a mechanism through which contestability can be delivered across digital ecosystems.

The practical focus of the Commission's intervention is notable. The objective is not interoperability as an abstract principle but interoperability that enables competing providers to access functionalities previously controlled by gatekeepers.

This emphasis reflects a broader feature of DMA enforcement. The Commission is increasingly concerned with operational access, technical implementation and user experience rather than formal commitments alone.

DMA Supervision Is Expanding Towards Digital Infrastructure

The reporting period also demonstrated a widening scope of regulatory attention.

In November 2025, the Commission launched market investigations into Amazon Web Services and Microsoft Azure to assess whether cloud computing services may warrant designation under the DMA despite not meeting the quantitative thresholds normally associated with gatekeeper status. Parallel investigations were also opened into practices within cloud markets more generally.

Cloud infrastructure occupies a different position in the digital economy from app stores, search engines or social networks. Its growing prominence within DMA discussions therefore signals an important development.

The focus is no longer limited to digital interfaces through which users access services. Attention is increasingly extending to infrastructure layers that shape the conditions under which digital markets operate.

The cloud investigations also demonstrate how the Commission is using DMA market investigation powers not only to assess existing obligations but to evaluate whether emerging market structures require additional regulatory intervention.

Regulatory Dialogue Remains Central

The expansion of enforcement activity has not displaced the role of regulatory dialogue.

Throughout 2025, the Commission continued to rely extensively on workshops, consultations and technical engagement with gatekeepers and third parties. Several compliance adjustments emerged through these processes without requiring formal infringement findings.

The closure of the Commission's investigation into Apple's implementation of browser choice and default-setting obligations provides an example. Following regulatory engagement, Apple modified a range of user choice mechanisms, leading the Commission to close the proceeding while continuing to monitor implementation.

This reflects an important feature of the DMA's institutional design. Enforcement and dialogue are not presented as alternative approaches. Rather, they operate as complementary mechanisms within the same supervisory framework.

The Commission's willingness to adopt formal decisions where necessary has strengthened the credibility of the wider dialogue process.

Towards Cross-Regime Digital Supervision

Another notable feature of the reporting period was the growing interaction between the DMA and other regulatory frameworks.

Cooperation intensified between competition authorities, data protection authorities and consumer protection bodies. Work also progressed on joint guidance concerning the relationship between the DMA and the General Data Protection Regulation.

These developments point towards a more integrated model of digital regulation.

Questions relating to market power, personal data, consumer choice and platform governance are increasingly being examined through overlapping regulatory frameworks rather than in isolation. The practical consequence is that compliance assessments are becoming more interconnected across policy domains.

For businesses operating in regulated digital markets, this trend may prove as consequential as any individual enforcement decision.

Outlook

The 2025 reporting cycle suggests that DMA supervision is entering a new phase.

The central issue is no longer whether gatekeepers have implemented compliance measures. Increasingly, the Commission is focused on whether those measures generate observable changes in market outcomes.

Interoperability, infrastructure services and cross-regulatory cooperation now occupy a prominent position within the Commission's supervisory agenda. Together, these developments indicate a gradual shift from implementation oversight towards outcome-based regulation.

As the DMA review process continues and investigations into cloud computing services advance, the next phase of enforcement is likely to be defined less by designation decisions and more by how the Commission measures effective contestability in practice.