The EU could unveil the Digital Markets Act as early as Thursday; sources say the DMA targets companies with €75B+ market cap and at least 45,000 active users
Digital Markets Act now expected to target core online platforms with market cap of at least €75bn
Context & Ripple Effects
This unveiling caps a legislative arc the coverage traces back to November 2021, when the EU approved the DMA's core mandates — social app interoperability, an ad-targeting ban for minors, and fines up to 20% of global annual sales approved by the EU that November. The €75bn market-cap and 45,000-user thresholds reported here define exactly which platforms fall inside the gatekeeper net.
The rulebook also travels: within a year of this report, the UK proposed a parallel bill giving its CMA digital markets unit power over firms with £25B+ global revenue the UK's CMA targeting bill, and by March 2024 the law was live enough that Brussels opened formal investigations into Apple, Google and Meta compliance the first formal DMA investigations — while Washington protested in writing but stopped short of a fight.
First-order effects
- U.S. internet giants clearing the €75bn/45,000-user thresholds become designated gatekeepers on day one, immediately obligated toward interoperability, data-separation and app-store rules rather than case-by-case antitrust findings.
- Compliance costs shift from legal defense to product engineering: the five targeted U.S. companies must restructure store policies, messaging APIs and ad-data practices specifically for the European market.
Second-order effects
- Regulators elsewhere get a template to copy — the UK's CMA bill with its £25B revenue trigger follows within weeks, turning ex-ante platform regulation from an EU experiment into a coordinated Western framework.
- The Biden administration, which sent two protest letters as the law took effect, faces pressure to either escalate diplomatically or accept that EU rules will effectively set operating terms for U.S.-headquartered platforms abroad.
Third-order effects
- If the pattern holds, platform regulation converges on statutory gatekeeper designations enforced continuously by dedicated units (DMA in the EU, CMA's digital markets unit in the UK), displacing the slower merger-and-abuse litigation model that defined Big Tech antitrust for two decades.
- Gatekeeper obligations become a durable feature of operating in Europe — opening the door to third-party app stores, browser competition and interoperable messaging as standing market structures rather than one-off concessions.
The trend: Major economies are replacing reactive antitrust cases with standing ex-ante gatekeeper regimes, with the EU's DMA as the template other regulators are now adapting.