Three 2026 Moments That Redefine DMA Enforcement
The Digital Markets Act (DMA) entered into force in 2022 and began applying to designated gatekeepers in 2024. Two years of live enforcement later, 2026 is the year the regime is stress-tested on three fronts at once:
- The first formal DMA review, due by May 3, 2026, which the Commission must deliver to the European Parliament, the Council, and the European Economic and Social Committee.
- Meta’s ad-personalisation choice, rolled out in January 2026 to EU users of Facebook and Instagram.
- Google’s compliance verdict, with the Commission’s final decision expected by July 27, 2026, following preliminary findings on interoperability and search data-sharing.
For tech teams, product leaders, and compliance officers at any company that depends on gatekeeper platforms (and many do, whether you sell on Amazon, build on Android, or advertise on Meta), these three tracks determine how the DMA actually bites in practice.
The First DMA Review: A Strategic Stocktake
Per Article 53 of the DMA and the Commission’s DMA portal, the Commission is required to evaluate the regulation by May 3, 2026, and every three years after that. The evaluation must:
- Assess whether the DMA’s aims — contestable and fair digital markets — have been achieved.
- Measure impact on business users, especially SMEs, and on end users.
- Consider whether to extend Article 7 to social networking services, and whether to modify the list of core platform services in Article 2.
- Review the obligations in Articles 5, 6, and 7 and their enforcement.
The Commission’s public consultation on the review received more than 450 contributions between July and September 2025 from SMEs, gatekeepers, civil society, academics, and citizens. Goodwin’s DMA review alert notes that the summary of those contributions was published on January 8, 2026 — setting the stage for the formal report.
Following the evaluation, the Commission may propose legislative changes. That is the piece every gatekeeper and every large business user is watching closely.
Meta’s January 2026 Ad Choice
Meta’s path under the DMA has been among the most litigated. In April 2025, the Commission fined Meta €200 million for its “pay or consent” advertising model. Regulators kept pushing, and from January 2026 Meta began offering EU users of Facebook and Instagram a third option: a less-personalised ad experience alongside the existing fully-personalised option and the paid ad-free subscription.
In December 2025, the Commission publicly called this revised less-personalised option “a very good step forward,” while continuing to monitor “the impact and uptake of this new ad model”. Coverage by The Current and TechBuzz AI frames the move as a concession to regulators, but also a signal that the “effective choice” language of the DMA is now a concrete product requirement, not an abstract principle.
For advertisers, this matters: a growing share of EU impressions will run on the less-personalised mode, which changes targeting effectiveness, frequency capping, and attribution. Media plans built in 2024 need to be revalidated for 2026.
Google’s July 27, 2026 Deadline
On January 27, 2026, the Commission opened proceedings to help Google address interoperability and online search data-sharing obligations under the DMA. TechPolicy.Press reports that preliminary findings were subsequently sent to Google, and that the Commission’s final decision is expected by July 27, 2026.
Three DMA obligations sit at the heart of the case:
- Search data sharing — gatekeepers running a core search engine must share certain ranking, click, and query data with rival search engines on FRAND terms.
- Interoperability — Google must enable effective interoperability with its operating system functionalities for third parties (relevant to Android developers).
- Self-preferencing — the ban on favouring a gatekeeper’s own services in rankings.
A non-compliance finding in July 2026 can trigger fines of up to 10% of global annual turnover under the DMA — which for Alphabet amounts to tens of billions of euros of potential exposure. Even if the final decision is less severe, the precedent will shape how Apple, Amazon, and the other gatekeepers approach their own remedies.
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The Cumulative Gatekeeper Picture
Per the CSIS analysis of the DMA, the DMA now applies to seven designated gatekeepers: Meta, Alphabet, Amazon, ByteDance, Apple, Booking, and Microsoft, across 23 core platform services. Each has its own DMA file:
- Apple and Meta were hit with the first DMA fines in April 2025 (€500M and €200M respectively), as summarised by TechPolicy.Press.
- Google faces the July 27, 2026 decision on search and interoperability.
- Amazon, Booking, Microsoft, ByteDance — each is in an active dialogue with the Commission on specific DMA obligations, with compliance reports published in March 2026.
The European Business Magazine summary flags that cumulative fine exposure across the seven gatekeepers is pushing the EU into politically sensitive territory — especially in the context of US-EU tech trade tensions.
What This Means for Non-Gatekeepers
Most companies reading this are not gatekeepers — but almost all are downstream users of gatekeeper platforms. The practical implications for 2026:
- [ ] App developers on Android / iOS — track how interoperability and in-app payment remedies evolve; procurement and contract timelines will shift.
- [ ] Advertisers on Meta / Google — model the impact of less-personalised inventory on ROAS; refresh first-party data strategies.
- [ ] Sellers on Amazon, hosts on Booking — monitor any changes to ranking, self-preferencing remedies, and data-access rights.
- [ ] Cloud and SaaS buyers on Microsoft — watch DMA-driven portability and interoperability commitments.
- [ ] Business users generally — the DMA review can expand core platform services (e.g., social networking under Article 7); some platforms you use today may fall in scope next.
What Non-Gatekeeper Companies Should Do Before July 2026
The DMA’s direct subjects are seven designated gatekeepers. Its indirect effects reach every company that uses gatekeeper platforms for advertising, distribution, cloud services, or app delivery — which includes most of the global digital economy. The following prescriptions are ordered by urgency relative to the three 2026 milestones.
1. Revalidate Ad Performance Assumptions on Meta Before Q3 Budget Locks
Meta’s January 2026 introduction of the less-personalised ad option will progressively shift a portion of EU impressions from behavioural targeting to contextual targeting. Advertisers who have not modelled the impact on ROAS for their EU audience are carrying an unquantified planning risk into their Q3 and Q4 budgets. The practical step is to segment EU campaign reporting by personalisation mode — Meta’s Ads Manager now provides impression-level signals about which inventory type delivered a given ad — and measure the performance differential. For most B2C advertisers, early data from Q1 2026 campaigns suggests a 10-25% ROAS reduction on less-personalised impressions versus fully personalised inventory. First-party data strategies — email lists, CRM audiences, on-site event tracking — mitigate this loss because they power Custom Audience and Lookalike targeting regardless of the personalisation model. Companies without a first-party data infrastructure running into the Q3 Meta budget cycle are the most exposed to the DMA-driven performance shift.
2. Audit Your Google Dependency Map Before the July 27 Decision
The Commission’s July 27, 2026 Google decision covers interoperability and search data-sharing obligations. A non-compliance finding may require Google to change how it surfaces third-party results, shares ranking signals with rival search engines, or opens Android functionalities to third parties. Companies whose discovery, revenue, or distribution depends heavily on Google search rankings, Google Ads, or Google Play should build a dependency map now — a documented breakdown of what share of traffic, leads, or downloads comes from each Google surface — and identify the 20% of dependencies that represent 80% of the business risk. This is not a prediction that the July decision will be adverse; it is prudent infrastructure mapping that should exist regardless of regulatory outcome. App developers who have not tracked their Play Store dependency since the Apple-Google DMA fine precedent in April 2025 are operating with less visibility into their revenue concentration than their investors expect.
3. Monitor the DMA Review for Scope Expansion Into Your Platform Category
The May 3, 2026 DMA review may recommend expanding the regulation’s scope to cover additional platform categories under Article 7 — specifically social networking services and potentially additional software platforms that have grown since the original gatekeeper designations. Companies operating platforms with significant European user bases should track the review’s recommendations, because a scope expansion in 2026 could trigger new gatekeeper designation proceedings in 2027-2028. The public consultation that closed in September 2025 received more than 450 contributions, many of which called for expanding DMA coverage to categories not currently designated. Legal and policy teams at mid-market platform companies who have dismissed the DMA as a concern relevant only to Big Tech should begin monitoring the review outcome as a pre-designation early-warning signal. Goodwin’s DMA review alert and the Commission’s DMA portal are the clearest public sources for tracking developments as the May 3 deadline approaches.
The Antitrust Question
The unresolved tension underneath the DMA’s 2026 milestones is whether ex-ante regulation of the kind the DMA represents is compatible with the economic reality of AI infrastructure. The seven designated gatekeepers — Meta, Alphabet, Amazon, ByteDance, Apple, Booking, and Microsoft — are also the primary funders of AI infrastructure buildout. The $122 billion OpenAI megaround, reported by Crunchbase in Q1 2026, came from a consortium that includes Microsoft. Amazon and Google are each committing tens of billions annually to their own AI infrastructure. Fining these companies under the DMA while simultaneously depending on their capital allocation for AI infrastructure is a structural tension the Commission has not resolved.
The antitrust question that the May 2026 review is likely to surface — but not answer — is whether DMA compliance obligations will begin to diverge from competition law as AI-era platform dynamics become clearer. The DMA was designed for 2021 market structures. By 2026, the gatekeepers have collectively become the primary providers of AI compute, model APIs, and agent platforms to the enterprises that regulators are trying to protect from gatekeeper power. A company using Microsoft Azure to deploy its AI agent and Microsoft Copilot Studio to configure it is simultaneously a DMA-protected business user and a Microsoft-dependent infrastructure consumer.
For non-gatekeeper companies, this tension has a practical implication: the DMA’s interoperability and data-portability obligations are the most important long-term lever, because they create the conditions under which switching costs can eventually fall. Tracking whether the July 2026 Google decision produces binding portability remedies — or merely fines that the company absorbs — will indicate whether the DMA’s ex-ante framework is producing structural change or revenue transfer.
Frequently Asked Questions
When will the European Commission publish its first DMA review?
Under DMA Article 53, the Commission is required to deliver its first review by May 3, 2026, and every three years after that. The review must be submitted to the European Parliament, the Council, and the European Economic and Social Committee, and may be followed by legislative proposals.
What changed with Meta’s advertising model in January 2026?
From January 2026, Meta began offering EU users of Facebook and Instagram an option for less-personalised advertising alongside the existing fully-personalised and ad-free paid options. This was a direct response to EU regulator pressure, following a €200 million DMA fine in April 2025.
What happens if Google misses the July 27, 2026 deadline?
The Commission’s final decision by July 27, 2026 will determine whether Google is in compliance with DMA obligations on interoperability and search data sharing. A non-compliance finding can carry fines of up to 10% of global annual turnover under the DMA, plus binding remedies and potential periodic penalty payments.
Sources & Further Reading
- European Commission — Digital Markets Act Latest News
- CSIS — Guarding the Gates: The Digital Markets Act and Lessons in Ex Ante Regulation
- TechPolicy.Press — Understanding the Apple and Meta Noncompliance Decisions under the DMA
- European Business Magazine — EU Prepares Tougher Tech Enforcement in 2026
- Goodwin — DMA Review Moves Forward (January 2026)
