Six Tech Giants File DMA Compliance Reports as EU Prepares First Review of Its Landmark Antitrust Law
All six DMA gatekeepers filed annual compliance reports on March 9 as the Commission prepares its first formal review of the regulation, with AI designation and transatlantic tensions at stake.
Overview
The six technology companies designated as gatekeepers under the European Union’s Digital Markets Act filed updated compliance reports with the European Commission on March 9, detailing the changes each has made over the past year to satisfy the regulation’s obligations on interoperability, data portability, and fair dealing with business users. Alphabet, Amazon, Apple, ByteDance, Meta, and Microsoft also submitted independently audited assessments of their consumer profiling techniques, according to the Commission’s announcement. A seventh gatekeeper, Booking.com, is expected to file at a later date.
The submissions arrive at a pivotal moment for the DMA. The Commission must deliver its first formal review of the regulation to the European Parliament, the Council, and the European Economic and Social Committee by May 3, and the outcome could reshape the law’s scope and enforcement machinery for years to come.
What the Reports Cover
Each gatekeeper’s filing addresses the 23 core platform services currently within the DMA’s regulatory perimeter, covering search engines, app stores, messaging platforms, advertising intermediation, operating systems, and social networks. The compliance reports describe technical and commercial measures taken over the preceding twelve months, while the consumer profiling audits provide independently verified accounts of how each company collects, combines, and analyzes user data across its services.
Public versions of the compliance reports and non-confidential summaries of the profiling audits are being published on the Commission’s dedicated DMA case portal. The Commission has said it will undertake a detailed analysis, gather input from third parties, and incorporate findings from its ongoing regulatory dialogues and enforcement proceedings.
The Enforcement Record So Far
The filings land against a backdrop of escalating enforcement. On April 23, 2025, the Commission issued its first noncompliance decisions under the DMA, fining Apple 500 million euros for blocking app developers from steering users to offers outside the App Store and Meta 200 million euros for offering a pay-or-consent advertising model that the Commission said deprived users of their right to freely give consent, according to the Commission’s press release.
Apple was found to have imposed technical and commercial restrictions that prevented developers from communicating alternative purchase options, including so-called scare screens designed to discourage users from choosing external links. The company’s fee structure, which at one point charged up to 17 percent on purchases made through alternative channels, was deemed disproportionate. Meta’s violation centered on Article 5(2) of the DMA, which requires gatekeepers to offer users a less personalized but equivalent alternative to targeted advertising. The Commission ruled that providing only a paid ad-free tier, initially priced at 9.99 euros per month on the web, did not constitute a genuine choice.
Both companies were given 60 days to comply or face periodic penalty payments of up to 5 percent of average daily worldwide turnover. Apple has appealed to the European General Court. Meta reached a settlement in December 2025 and launched a revised advertising model in January 2026 that includes two free tiers, one with personalized ads and one with less personalized but unskippable advertisements, though the Commission continues to evaluate whether this satisfies the regulation.
Additional proceedings remain open. The Commission has sent preliminary findings to Alphabet regarding self-preferencing in Google Search and anti-steering practices in Google Play, and has flagged further concerns about Apple’s Core Technology Fee, a 0.50-euro-per-install charge on alternative app distribution that Epic Games documented requires more than 15 steps to complete.
The May Review and the AI Question
The Commission’s first triennial review, due May 3, will assess whether the DMA has achieved its goals of contestable and fair digital markets, evaluate its impact on business users and SMEs, consider whether interoperability obligations should be extended to online social networking services, and determine whether the list of core platform services needs to be modified, according to the Commission’s consultation summary.
The review drew more than 450 contributions from stakeholders. Among the most closely watched questions is whether generative AI should be designated as a core platform service. France, Germany, and the Netherlands have publicly advocated for including integrated AI services and cloud providers, citing the importance of computing power for large AI models. Proponents argue that integrating AI into existing gatekeeper ecosystems, from Google’s Gemini in Search to Microsoft’s Copilot, creates data advantages that current DMA provisions cannot reach because Article 5(8) restrictions on data cross-use apply only to designated services.
Opponents counter that the DMA’s consent and data-sharing rules were not designed for AI training pipelines and that designation could cause providers to limit feature rollouts in the EU. Cloud computing, already listed as a core platform service category, could offer an alternative path: designating specific providers like Amazon Web Services and Microsoft Azure, both of which face ongoing market investigations, would address upstream concentration without creating an entirely new service category.
Transatlantic Friction
The enforcement trajectory has intensified diplomatic tensions. Five of the seven designated gatekeepers are American companies, and the Trump administration has characterized the DMA’s enforcement actions as discriminatory targeting of U.S. technology champions. President Trump threatened 25 percent tariffs on EU technology companies in response to the cumulative 4.3 billion euros in fines levied against Google alone, while U.S. Trade Representative Jamieson Greer has called the regulations unacceptable discrimination, according to a CSIS analysis.
The same CSIS analysis estimated that compliance costs of 1 to 2 percent of global revenue could translate to 8 to 13 percent of EU revenue for American gatekeepers, potentially affecting 34,000 to 56,000 jobs and costing up to 50 billion dollars. Commission President Ursula von der Leyen has publicly committed to proceeding regardless of company origin or leadership, but the political calculus has grown more complex as the review approaches.
What Comes Next
The Commission’s analysis of the March 9 compliance reports will feed directly into the May review and could inform new enforcement actions or specification proceedings. If the review recommends expanding the DMA’s scope to include AI, any legislative amendment would require approval from both the European Parliament and the Council, a process that typically takes 12 to 18 months.
In the meantime, the regulation’s existing enforcement tools remain potent. Maximum penalties can reach 10 percent of worldwide turnover for noncompliance and up to 20 percent for repeat offenses. The DMA also enables private enforcement at the member state level, with Germany and the Netherlands already pursuing cases. The compliance reports filed this week will determine whether the gatekeepers’ adjustments satisfy the Commission or trigger the next round of proceedings in what has become the most consequential technology regulation since the General Data Protection Regulation.