Will the Digital Markets Act Inspire Global Tech Reform?

27 July 2026

The European Union's Digital Markets Act (DMA) is not just another piece of regulation. It is the most ambitious attempt in decades to reshape how the world's largest technology companies operate. Since it took full effect in March 2024, the DMA has forced Apple to open its App Store, required Google to offer choice screens for search engines, and compelled Meta to ask for consent before combining user data across its services. The question now is whether this experiment in Brussels will spill over into other jurisdictions, or remain a European outlier.

The short answer is yes, but not in the way most people expect. The DMA is already inspiring global tech reform, but through a mix of direct copying, indirect pressure, and unintended consequences. To understand how and why, you need to look beyond the headlines about fines and compliance deadlines. You need to examine the mechanics of the law, the incentives it creates, and the strategic responses of the gatekeepers themselves.

How the DMA Actually Works (and Why It Matters Globally)

The DMA designates companies as gatekeepers if they operate a core platform service, have a strong economic position in the EU, and are entrenched. That means a platform with more than 45 million monthly active users in the EU, a market capitalization above 75 billion euros, and a track record of providing a service that is a gateway for businesses to reach end users. Apple, Google, Meta, Amazon, Microsoft, and ByteDance (TikTok) all qualify.

Once designated, gatekeepers face a list of do's and don'ts. They must allow third-party app stores, give users real choices over default browsers and search engines, make messaging services interoperable, and stop self-preferencing their own products. They cannot combine personal data across different services without explicit consent, nor can they use non-compete clauses to lock in business users.

The key insight is that the DMA is not about punishing bad behavior after the fact. It is a structural regulation that rewrites the rules of the digital economy ex ante. That is a radical departure from the US approach, which relies on antitrust enforcement through court cases that take years. The EU decided that waiting for a monopoly to be proven and then broken up is too slow. Instead, they wrote the rules first and forced compliance.

This structural approach is what makes the DMA a template for other countries. Japan, India, Brazil, the United Kingdom, and even the United States are now considering similar legislation. Japan's proposed bill targets app store monopolies almost verbatim from the DMA. India's Digital Competition Bill borrows heavily from the DMA's designation criteria. The UK's Digital Markets, Competition and Consumers Act, which passed in 2024, uses the same ex ante framework with a designated conduct regime.

The Direct Inspiration Effect: Copying the EU Playbook

The most obvious way the DMA inspires global reform is through direct legislative copying. Lawmakers in other countries face the same problems: Apple and Google control mobile distribution, Meta dominates social advertising, Amazon rules e-commerce infrastructure. The DMA offers a ready-made solution that has already been tested in legal challenges and real-world implementation.

Take Japan. In 2024, the Japanese government proposed a bill that would require Apple and Google to allow third-party app stores and alternative payment systems on mobile devices. The language mirrors the DMA's Article 6 obligations. The reasoning is the same: developers should not be forced to pay 30% commissions to reach users. The Japanese Fair Trade Commission explicitly cited the DMA as a model.

Brazil is further along. Its Bill 2768/2022, which targets digital platforms, uses the DMA's definition of gatekeepers and includes similar prohibitions on self-preferencing and data combination. The Brazilian Congress has held hearings with EU regulators to understand the DMA's enforcement mechanisms.

India's draft Digital Competition Bill, released in 2023, goes even further. It proposes a system where the government designates systemically important digital intermediaries based on revenue, user base, and market impact. The criteria are almost identical to the DMA's quantitative thresholds. The bill also includes obligations on interoperability, data portability, and non-discrimination that are lifted directly from the EU text.

The UK, now outside the EU, has its own Digital Markets Unit and the Digital Markets, Competition and Consumers Act. While not identical, the UK regime gives the Competition and Markets Authority the power to designate firms with strategic market status and impose conduct requirements. The UK regulator has already signaled it will look at the same issues as the DMA: app stores, advertising technology, and search.

Why the US Is the Real Battleground

The United States is the most important jurisdiction for global tech reform, and the DMA's influence there is more complex. The US has a long tradition of antitrust enforcement based on consumer welfare, not competitor protection. The DMA, by contrast, protects both competitors and consumers, and it does so through regulation rather than litigation.

Several US bills have tried to replicate the DMA's approach. The Open App Markets Act, which failed to pass in 2022 and 2023, would have forced Apple and Google to allow sideloading and alternative payment systems. The American Innovation and Choice Online Act targeted self-preferencing by dominant platforms. Both bills died in committee, largely due to intense lobbying from the tech industry.

But the DMA's influence is still felt in the US through the courts. The Department of Justice's antitrust case against Google over search distribution, and the case against Apple over app store monopoly, now have a real-world example of what regulation looks like. The EU's decisions against Google in Android and shopping cases provided evidence for US prosecutors. The DMA's success in forcing behavioral changes gives US enforcers concrete examples of what remedies can achieve.

More importantly, the DMA creates a race to the top for global standards. If Apple must allow third-party app stores in Europe, it is cheaper and simpler for the company to offer the same functionality worldwide than to maintain separate operating systems. Apple already does this with privacy features introduced in Europe that later became global defaults. The same logic applies to compliance with the DMA. Once the technical work is done for the EU, the marginal cost of extending it to other markets is low.

The Indirect Pressure: Gatekeepers Change Their Behavior Globally

The most powerful effect of the DMA may not be the laws it inspires, but the behavioral changes it forces on gatekeepers. These companies operate globally. When they redesign their products for the EU, those changes often roll out worldwide because it is inefficient to maintain multiple versions.

Consider Apple's decision to allow web distribution of iOS apps in the EU. Apple created a new framework for app distribution that includes a reduced commission, alternative payment processing, and a core technology fee. While this is only required in the EU, Apple has indicated it will offer similar terms to developers in other regions who want to distribute their apps through the web. The technical infrastructure is already built.

Google did something similar with its choice screen for search engines. In the EU, Android users are shown a screen asking them to pick their default search provider. Google expanded this to other markets, including the UK and Turkey, partly to preempt similar regulatory demands. The company realized that offering choice proactively was better than being forced to do so later.

Meta's approach to data consent is another example. The DMA requires Meta to ask users for permission before combining data from Facebook, Instagram, and WhatsApp for targeted advertising. Meta implemented this in the EU in 2024. The company is now considering extending the same consent model to other regions, partly because it simplifies its data governance and partly because other regulators are watching.

Amazon has changed its ranking algorithms for the EU to reduce self-preferencing of its own products. These changes are visible to all sellers, not just those in Europe. Amazon cannot easily separate its search and ranking systems by geography. The algorithmic adjustments made for the DMA affect the entire marketplace.

The Unintended Consequences: What the DMA Gets Wrong

No major regulation is perfect, and the DMA has significant flaws that other countries should study carefully. The most serious problem is the risk of regulatory fragmentation. If every country passes its own version of the DMA, with different definitions, thresholds, and obligations, gatekeepers will face a compliance nightmare. The cost of adapting to dozens of distinct regimes will be passed on to users and developers.

The DMA also creates a two-tier internet. Services available in the EU may differ significantly from those in other regions. Some companies have already chosen to withhold features from the EU rather than comply. Apple delayed the release of its AI features in Europe, citing DMA compliance concerns. Meta threatened to pull news content from Facebook and Instagram in the EU. These are negotiating tactics, but they highlight a real tension: regulation can lead to deglobalization of digital services.

Another flaw is the DMA's focus on size. The regulation targets companies based on revenue and user counts, not on actual market power. This means a company like Booking.com, which dominates European travel booking, is a gatekeeper, while a smaller competitor with more anticompetitive behavior is not. The quantitative thresholds are arbitrary and can be gamed.

The interoperability requirements are particularly problematic. The DMA forces messaging services to be interoperable. In theory, that means WhatsApp users could message Telegram users. In practice, achieving end-to-end encryption across different platforms is technically extremely difficult. The DMA's deadlines for interoperability may force companies to weaken security or ship incomplete solutions.

Best Practices for Countries Considering DMA-Style Reform

If you are a policymaker in a country considering digital market regulation, the DMA offers several lessons. First, do not copy the DMA verbatim. Adapt it to your local market conditions. The EU's approach works for a large, integrated market with strong consumer protections. A smaller market with different competitive dynamics may need different thresholds and obligations.

Second, invest in enforcement capacity. The DMA is only as strong as the European Commission's ability to enforce it. The Commission has a dedicated Digital Markets Unit with dozens of staff. Smaller regulators will need similar expertise in economics, technology, and law. Without that, gatekeepers will outmaneuver the regulator through legal challenges and technical complexity.

Third, focus on interoperability standards. The DMA's interoperability requirements are the most transformative but also the most technically challenging. Countries should work together to develop common standards for messaging, data portability, and advertising transparency. Otherwise, each country will demand different technical solutions, and interoperability becomes impossible.

Fourth, include sunset clauses and review mechanisms. The DMA is a living regulation that will need updating as technology evolves. The European Commission is required to review the DMA every two years. Other countries should build similar review processes so the law can adapt to new business models like AI assistants, virtual reality platforms, and decentralized finance.

What Businesses Should Do Now

For companies that operate in digital markets, the DMA is not a distant European concern. It is a preview of the global regulatory environment. If you are a developer, a startup, or a mid-size platform, you should prepare for a world where gatekeepers are forced to open their ecosystems.

Start by auditing your dependencies on gatekeeper platforms. If your business relies on Apple's App Store for distribution, Google's search for traffic, or Meta's ad network for customers, you need to understand how the DMA changes your options. The DMA gives you the right to use alternative payment systems, to distribute outside official app stores, and to demand data portability. These rights are valuable, but only if you are ready to exercise them.

Build technical capabilities for multi-platform distribution. The DMA creates opportunities for alternative app stores, direct web distribution, and cross-platform messaging. Your engineering team should be able to deploy on multiple channels without being locked into a single gatekeeper's ecosystem.

Pay attention to the consent requirements. The DMA forces gatekeepers to get explicit consent for data combination. That changes the advertising landscape. If you rely on targeted ads, you may see changes in how audiences are built and how campaigns are measured. Prepare for a world where user consent is the default, not the exception.

Finally, engage with regulators. The DMA is still being interpreted. The European Commission is issuing guidance on everything from what constitutes a self-preference to how interoperability should work. Companies that participate in consultations and submit technical evidence can shape the rules. The same will be true in other jurisdictions as they develop their own versions of the DMA.

The Big Picture: A New Global Standard

The DMA is not the end of tech regulation. It is the beginning of a new era where governments actively shape the structure of digital markets. The question is not whether the DMA will inspire global reform, but how messy and fragmented that reform will be.

The best-case scenario is a gradual convergence around the DMA's core principles: ex ante rules for gatekeepers, interoperability, data portability, and fair access. This would create a global baseline that reduces compliance costs and gives developers and consumers consistent rights regardless of where they are.

The worst-case scenario is a patchwork of incompatible regulations that fragment the internet and increase costs for everyone. That outcome is not inevitable, but it requires active cooperation between regulators, something that is historically difficult.

The DMA's real legacy will be determined not in Brussels, but in Tokyo, New Delhi, Brasilia, and Washington. If those capitals adopt smart, adaptable versions of the DMA, the result will be a more competitive and open digital economy. If they copy the flaws without learning from the EU's early mistakes, the result will be confusion and backlash.

For now, the DMA is the best template we have. It is imperfect, but it is a serious attempt to solve a real problem: the concentration of power in a handful of private companies that control the infrastructure of the digital age. Whether that template becomes a global standard depends on how well its successors learn from both its successes and its failures.