Seven companies, 23 services: what the EU Digital Markets Act requires of gatekeepers
The EU's Digital Markets Act sets size thresholds for large platforms, but the European Commission makes the formal decision that names a gatekeeper and lists the services it covers.
The Digital Markets Act is an EU regulation, numbered 2022/1925, that targets large online platforms called gatekeepers. It sits alongside competition law and applies to a defined list of services known as core platform services.
Whether a company is a gatekeeper depends on size thresholds set in Article 3 and a formal designation decision by the European Commission. The Commission's gatekeeper page lists seven designated companies, covering 23 core platform services. The figures below come from the regulation text, the Commission's own pages and news reports of its decisions.
The size thresholds in Article 3
Article 3 sets out three size routes. The turnover route requires annual Union turnover of at least €7.5 billion in each of the last three financial years. The market-value route requires average market capitalisation, or equivalent fair market value, of at least €75 billion in the last financial year.
The turnover and market-value routes also require the same core platform service to be provided in at least three Member States.
The user route applies to services with at least 45 million monthly active end users established or located in the Union, and at least 10,000 yearly active business users established in the Union. Those user thresholds must be met in each of the last three financial years.
Meeting all of these thresholds is the trigger for a duty to notify the Commission, which is covered in the next section.
How the Commission designates a gatekeeper
A company that meets the thresholds must notify the Commission without delay, and in any event within two months. The Commission then has 45 working days, counted from receipt of complete information, to decide whether to designate it.
The Commission's DMA page says the regulation became applicable on 2 May 2023, and that companies providing core platform services existing by that date had to notify within two months. Companies that meet the thresholds later must notify within two months of doing so.
Designated gatekeepers have up to six months after the decision to comply with their duties.
The Commission describes the framework as using clearly defined, objective criteria to identify gatekeepers. Its gatekeeper page links to a designation decision for each company, so the covered services can be checked against the decision itself.
Who is designated today
On 6 September 2023 the Commission designated Alphabet, Amazon, Apple, ByteDance, Meta and Microsoft. Apple's iPadOS was designated separately on 29 April 2024, and Booking was designated on 13 May 2024.
The covered services include Google Search, Google Play, Google Maps, YouTube and Chrome for Alphabet; Marketplace and Amazon Advertising for Amazon; the App Store, iOS and Safari for Apple; TikTok for ByteDance; Facebook, Instagram, WhatsApp, Messenger and Meta Ads for Meta; LinkedIn and Windows PC OS for Microsoft; and online intermediation services for Booking.
On 23 April 2025 Meta was undesignated for one service, Facebook Marketplace, which shows that designation is set service by service. A Digital Policy Alert summary says the Commission released its third annual DMA report on 21 May 2026, covering 2025 activity, and that seven gatekeepers remained designated.
The list also includes ByteDance, which the Commission's page associates with TikTok.
Duties that apply once a company is designated
The Commission's DMA page sorts the duties into things gatekeepers must do and things they must not do. The must-do items include allowing third parties to interoperate with certain services, giving business users access to the data they generate, and letting business users promote offers and conclude contracts outside the platform.
The prohibitions include ranking the gatekeeper's own products above third-party offers. They also bar tracking end users outside the core service for targeted advertising without effective consent.
The Commission's page gives examples of core platform services such as online search engines, app stores and messenger services. Designation is set out service by service, so a company can be designated for some services and not others.
“Meeting the numbers starts a process, and the Commission still makes the designation decision.”
Fines, periodic penalties and the April 2025 decisions
The regulation allows fines of up to 10% of a gatekeeper's total worldwide annual turnover. The ceiling rises to 20% for repeat infringements, and periodic penalty payments can reach 5% of average daily turnover.
For systematic infringements, the Commission can open a market investigation and impose behavioural or structural remedies, including divestiture of parts of a business. Non-financial remedies are a last resort, according to the Commission's page.
On 23 April 2025 the Commission fined Apple €500 million over anti-steering rules in its App Store. Those rules stopped developers from telling users about alternative and often cheaper offers elsewhere. Apple was also ordered to remove technical and commercial restrictions on steering.
The same day, the Commission fined Meta €200 million over a consent-or-pay model that covered March to November 2024.
Both companies were given 60 days to comply or face periodic penalties. The Commission was still reviewing a revised Meta model from November 2024. The RTTNews report does not say whether either company will appeal.
Why the rules matter beyond Europe
The thresholds count users and business users established or located in the Union, but the fine ceiling is based on worldwide turnover. Revenue from outside Europe is therefore part of the base for the maximum fine.
For developers and users elsewhere, the April 2025 decisions show where the Commission acted in 2025: app store steering and advertising consent. The prohibitions on self-preferencing and cross-service tracking are also in the regulation, but the RTTNews report describes the April 2025 decisions as concerning anti-steering and consent-or-pay.
The Commission's 2026 annual report covers 2025 activity.
The same company can be designated for some services and not others, and designation rests on the Article 3 thresholds and a Commission decision.
