·DMA

Gatekeeper designation: thresholds, obligations, and what remains open

The Digital Markets Act targets a deliberately small set of platforms. How designation works in practice — and what the regulation leaves unresolved — matters for companies approaching the thresholds.

How designation works

Gatekeeper status follows from either quantitative thresholds (annual turnover and user numbers) or the Commission’s own assessment that a platform holds entrenched and durable market power. The Commission has sole jurisdiction over this process. Once designated, companies face obligations covering interoperability, data access, self-preferencing, and transparency. Non-compliance carries fines of up to 10% of global turnover; repeated violations can trigger structural remedies including divestiture.

The DMA’s thresholds were designed around a specific set of platforms. But the regulation applies to core platform services, not to named companies. How the Commission interprets the thresholds as new services scale is still being established.

What the DMA leaves unaddressed

The regulation does not address platform power below the gatekeeper threshold. Companies competing with designated gatekeepers but not themselves designated operate in an environment where their competitors carry obligations they do not. That structural asymmetry is built into the regulation’s scope.

Regulatory Reality · 2026 · Observational analysis. Not legal advice.