The compliance deadline for the six tech giants regulated under the EU's Digital Markets Act (DMA) expired yesterday. Which means Alphabet/Google, Amazon, Apple, ByteDance/TikTok, Meta and Microsoft are now under active evaluation by EU law enforcement.
The bloc will monitor whether they comply with DMA requirements to deal fairly with business users of their regulated platform services and meet other legal requirements in areas such as data portability, platform interoperability and user choice. Failure to do so risks significant fines – up to 10% or even 20% of its global annual turnover.
The first batch of gatekeeper compliance reports — also known as unclassified versions — have been published on the Commission's DMA website. (See below for links to individual reports.)
These reports provide different levels of detail on actions taken in response to the regulation to date. Apple's report is the shortest ever (just a 12-page summary, focusing on changes to the App Store, iOS and Safari, although written in easy-to-read prose), while Microsoft opted for multi-part reports – dividing up the disclosures. In a series of separate documents, relating to two specific platform services (Windows and LinkedIn).
While Apple is using the public report as another opportunity to protest EU-mandated changes to its “end-to-end system” — warning that the DMA creates “new avenues for malware, fraud, illicit and harmful content, and other privacy and security threats” — Microsoft’s reports appear to be aimed at… Until it is so boring that no one can bother to read it. In addition to being divided into multiple downloads, its compliance disclosures are written in dry legal language and include redactions, indicating that it has chosen to reproduce formal submissions to the Commission for this general part of the DMA's reporting obligations. Also noteworthy is the sheer total page count.
Elsewhere, Amazon produced the glossiest report, wrapping its DMA disclosures in a graphical shell of photos, charts and quotes — to give it a distractingly “easy-to-navigate” commercial feel.
Google's report is over 200 pages long, and is very long and dense. It's also not very visually appealing, as it's written in light gray text with extensively hyperlinked footnotes, as well as being augmented with screenshots, charts, and outside boxes. The length is at least justified: reflecting the fact that eight of its products are classified as core platform services.
Social networking giants Meta and ByteDance have fewer regulated services, so, it is not surprising that their reports reach an average length.
ByteDance's report reads like a raw, cleaned-up legal text, with no effort to polish anything, while Meta has applied its usual thick PR sheen. The report begins with a summary of the number of employees (11,000) and engineering/technical hours (590,000) it claims has applied to work on its DMA response. It also loads the document at the top of the page with a heavy spin on the “new and meaningful choices” it claims to be offering European users in response to the law.
It's unfortunate for the committee's enforcers whose jobs require wading through all these disclosures — and debating a lot of information — to determine whether or not the tech giants are actually DMA compliant.
For your useful reference, we have compiled links to the first batch of DMA compliance reports to the public below.
If you are looking for an analytical overview of the DMA, its goals and early effects, see our previous explainer.
Links to DMA Compliance Reports for Gatekeeper:
Alphabet/Google (211 pages)
Amazon (32 pages)
Apple (12 pages)
ByteDance/TikTok (52 pages)
Meta (57 pages)
Because Microsoft is Microsoft, it divides the DMA's non-confidential compliance reports into several separate documents: Summary (13 pages); Windows PC (164 pages); LinkedIn (244 pages) – 421 pages in total.
Additionally, Microsoft has published five additional documents disclosing audits of consumer profiling technologies used in its platform services (here, here, here, here, and here), the last two of which were written by the third party it participated in the audits (Deloitte) – Adding another 104 pages to its reporting tally, or 525 pages in total for this round of reports.
