Digital Markets Act (DMA): Key Milestones Across Three Years Of Implementation

Nearly three years have passed since the Digital Markets Act (the "DMA") entered into force, and digital markets have undergone radical transformation during this period. In response, the European Commission (the “Commission”) has been closely monitoring and evaluating these developments, publishing DMA Annual Reports to assess the progress made, pursuant to Article 35 DMA.

To date, the Commission has published three Annual Reports, each documenting a distinct phase of progress towards achieving the objectives set out in the DMA.

DMA Annual Report 2023 – Laying the foundations

The first DMA Annual Report covers the initial year in which the DMA became applicable. Specifically, it sets out the monitoring activities undertaken by the Commission during the reporting period, the cooperation and coordination mechanisms established between the Commission and national competition authorities (the "NCAs"), and the work performed by the High-Level Group for the Digital Markets Act. According to DMA Annual Report 2023, during the first year of DMA implementation, six gatekeepers (Alphabet, Amazon, Apple, ByteDance, Meta and Microsoft) were formally designated and became subject to compliance obligations under Articles 5, 6, 7, 14 and 15 DMA, with a compliance deadline of 7 March 2024. Notably, during the reporting period, no NCA formally notified the Commission of investigative measures or expressed its intention to launch an investigation under national competition law concerning a designated gatekeeper, indicating a coordinated enforcement approach at the outset. Finally, the 2023 Report documented the establishment of the High-Level Group for the Digital Markets Act. Constituted as a group of experts, the High-Level Group was tasked with supporting the coherent and effective implementation of the DMA.

DMA Annual Report 2024 – Moving into enforcement

The year 2024 marked a turning point for the DMA, according to the DMA Annual Report 2024. After spending the first year identifying which major tech companies qualify as "gatekeepers" the Commission decisively moved into enforcement mode. Specifically, two new gatekeepers were designated, namely Booking.com in respect of its online intermediation service, as well as Apple's iPad operating system (iPadOS). Moreover, the Commission launched six non-compliance investigations against Alphabet, Apple, and Meta to determine whether these gatekeepers have fulfilled their obligations under the DMA. At the same time, the Commission engaged extensively with gatekeepers and a broad range of stakeholders, including business users, developers, civil society organisations, and trade associations, through regulatory dialogue and compliance workshops. Finally, the High-Level Group for the Digital Markets Act further reinforced collaborative oversight by establishing three thematic subgroups focused on data, interoperability, and artificial intelligence.

DMA Annual Report 2025 – Materialisation of benefits

Eventually, on 21/05/2026, the Commission published the DMA Annual Report 2025, covering the Commission's activities during that year. Whereas 2023 and 2024 were characterised by the work of establishing the DMA's regulatory framework (e.g. designation of gatekeepers, initiation of regulatory dialogues), 2025 was the year in which many of the DMA's practical benefits for business users and end users began to materialise. Among the notable developments of the year, the Commission and the NCAs continued their close cooperation within the framework of the European Competition Network, with the Commission receiving nine notifications of national cases under Article 38 DMA. It is also worth noting that, the Commission and the European Data Protection Board ("EDPB") adopted joint guidelines on the interplay between the DMA and the General Data Protection Regulation ("GDPR"), recognising that, while the two instruments pursue distinct objectives, those objectives are highly complementary and mutually reinforcing.

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