Short answer
A practice breaches the Digital Markets Act (DMA) when a designated gatekeeper, acting through a listed core platform service, conflicts with a duty in Articles 5, 6 or 7. Those duties include anti-steering, ranking, data-access and interoperability rules. A complainant need not prove dominance again or reconstruct an Article 102 effects case.
The same practice breaches EU competition law only if its separate elements are proved. Unilateral conduct normally requires dominance and abuse under Article 102 TFEU; genuine coordination may engage Article 101. Market definition, context, effects and justification remain important.
The regimes can apply together. The DMA expressly preserves Articles 101 and 102 TFEU. But neither breach automatically establishes the other: DMA liability is tied to gatekeeper designation, a listed service and a specified obligation, while competition law applies more broadly but requires its own market-and-conduct analysis.
That separation matters because a Commission DMA finding does not substitute for market-specific competition-law proof.
Start with the actor and the service
Regulation (EU) 2022/1925 applies after the Commission designates a gatekeeper and lists the relevant core platform service. The service must be offered to EU-established business users or EU-established or located end users. Compliance is generally due six months after listing.
That scope check is decisive. A ranking change in a listed online search engine may fall under the DMA. The same change in a service that has not been listed does not become a DMA breach merely because the provider is large. Competition law may still apply if the provider is dominant in a relevant market and its conduct is abusive.
Which DMA obligation matches the practice?
The label attached to a practice is less important than its design and effect. The main DMA rules separate several recurring problems.
Ranking and self-preferencing
Article 6(5) directly addresses favourable treatment in search and ranking:
“The gatekeeper shall not treat more favourably, in ranking and related indexing and crawling, services and products offered by the gatekeeper itself than similar services or products of a third party. The gatekeeper shall apply transparent, fair and non-discriminatory conditions to such ranking.” —
The comparison concerns the gatekeeper’s own and similar third-party offerings, including indexing and crawling. A neutral relevance improvement is not automatically self-preferencing. Evidence should identify comparable results, treatment of origin and the ranking conditions.
Anti-steering
Articles 5(3) to 5(5) protect a business user’s ability to offer different prices or conditions through other channels, communicate and promote offers to acquired users, conclude contracts with them, and let users access content or subscriptions bought elsewhere. Article 5(7) also prevents a gatekeeper from forcing use of its identification, browser-engine or payment services in specified circumstances.
This reaches more than a clause saying “do not link out”. Interface design, warning screens, fees, eligibility rules or technical friction can be relevant if they prevent effective communication or contracting. The legal question is whether the measure conflicts with the specific obligation, not whether the gatekeeper calls it a commission rule or a security feature.
Interoperability
Article 6(4) covers installation and effective use of third-party applications and application stores. Article 6(7) requires free and effective interoperability with operating-system, virtual-assistant, hardware or software features available to the gatekeeper’s own services. Article 7 adds staged interoperability duties for designated number-independent interpersonal communications services.
These duties do not require exposing every system without safeguards. Articles 6 and 7 preserve specified integrity, security and privacy measures where strictly necessary, proportionate and justified. A general cybersecurity assertion is insufficient; the restriction, threat and alternatives should be documented.
Data use and access
Article 6 contains different duties for different data relationships. A gatekeeper must not use non-public business-user data to compete with those users. Advertisers and publishers can request access to performance tools and verification data. End users have portability rights. Business users can request high-quality, continuous and real-time access to data generated through their activity, subject to specific conditions for personal data. A third-party search engine can request ranking, query, click and view data on fair, reasonable and non-discriminatory terms, with personal data anonymised.
The question is who requested which data, in what role and for which listed service, and whether consent, anonymisation or another qualification applies. The DMA does not displace the General Data Protection Regulation.
What current DMA enforcement shows
On 23 July 2026, the Commission found that Google favoured its own services in Search and restricted app developers' steering from Google Play, imposing fines of EUR 460 million and EUR 430 million respectively. The official records identify and , but their public decision texts were unavailable on the review date. The findings should not be extended beyond the published description.
On 16 July 2026, binding Article 8 decisions specified and . They illustrate how security, privacy, anonymisation and access mechanics can be specified without converting the DMA inquiry into an Article 102 case.
What must be proved under competition law?
The DMA deliberately leaves EU competition law available:
“This Regulation is without prejudice to the application of Articles 101 and 102 TFEU.” —
Article 101 is relevant where undertakings agree or coordinate on a restriction—for example, where a platform clause forms part of an agreement and restricts competition. Purely unilateral conduct does not become an Article 101 agreement merely because it appears in imposed terms.
Article 102 usually supplies the competition-law framework for unilateral platform conduct. The undertaking must be dominant in a properly defined market; dominance itself is lawful. The practice must then be abusive and capable of affecting trade between Member States. For exclusionary conduct, the Court of Justice requires evidence tied to the conduct and its market context:
“it is necessary, as a rule, to demonstrate, through the use of methods other than those which are part of competition on the merits between undertakings, that that conduct has the actual or potential effect of restricting that competition by excluding equally efficient competing undertakings from the market or markets concerned, or by hindering their growth on those markets” —
In that 2024 Google Shopping appeal judgment, the Court upheld the assessment of favourable positioning of Google's comparison-shopping results alongside demotion of rivals. Traffic, user attention, network effects and irreplaceable search traffic helped show departure from competition on the merits and potential exclusion. It does not make self-preferencing a per se infringement.
On 2 July 2026, the Court also . The surviving findings concerned tying and licence conditions, including anti-fragmentation obligations. That judgment remains a contextual Article 102 ruling, not a DMA determination or a general ban on platform integration.
Article 102 also addresses exploitative conduct. In , the Commission found that Apple's anti-steering provisions for music-streaming app developers constituted unfair trading conditions detrimental to consumers.
That is an addressee-specific Commission decision, not a Court of Justice judgment or a rule that every steering restriction is abusive. Its market definition, dominance finding, terms and consumer harm remain part of the legal assessment.
When can both regimes apply?
Overlap is most plausible where all of the following are present:
- the provider is a designated gatekeeper and the affected service is listed;
- the practice falls within a concrete DMA duty—for example Article 6(5) ranking or Article 5 anti-steering;
- the provider is also dominant in a competition-law market; and
- the evidence establishes an Article 101 restriction or an Article 102 abuse under the relevant test.
The DMA route is more prescriptive. It does not require a fresh dominance finding or the same proof of actual or potential foreclosure for every obligation. Article 102 is more fact-dependent but is not confined to designated gatekeepers, listed services or the DMA’s closed set of obligations. A practice can therefore be DMA-only, competition-law-only, both, or neither.
A practical assessment checklist
- Identify the exact gatekeeper designation and listed core platform service.
- Map the conduct to the precise paragraph in DMA Articles 5, 6 or 7.
- Separate technical design from its stated rationale and practical operation.
- For data, identify the requester, data category, purpose, consent and anonymisation requirements.
- For interoperability or security restrictions, test necessity, proportionality and documentation.
- Ask whether the conduct is unilateral or genuinely agreed or coordinated.
- For Article 102, define the market, establish dominance, classify the alleged abuse and test effects in context.
- Keep Commission DMA enforcement and competition proceedings conceptually separate, even where the evidence overlaps.
Conclusion
Ranking, interoperability, data-access, anti-steering and self-preferencing practices breach the DMA when a designated gatekeeper violates the specific rule governing its listed service. They breach competition law only when the separate requirements of Article 101 or 102 are established. The DMA expressly allows both regimes to operate, but it does not collapse them into one test. The safest analysis begins with designation and the exact DMA paragraph, then separately examines agreement, market definition, dominance, competitive harm and justification. That separation shows whether the answer is DMA, competition law, both—or neither.
Sources
This article provides general legal information, not advice for a specific matter. Laws, facts and procedural deadlines may change the result. Follow the linked primary sources and obtain local advice before acting.