What Happened
The EU's Digital Markets Act, fully enforceable since March 2024, designated Alphabet, Amazon, Apple, ByteDance, Meta, and Microsoft — later joined by Booking.com — as "gatekeepers" subject to structural obligations: interoperability, data portability, and fair access conditions imposed upfront, rather than penalties pursued after the fact through antitrust litigation. The European Commission has since moved into active enforcement, fining Apple €500 million in April 2025 for anti-steering violations and Meta €200 million over its consent-or-pay advertising model.
Similar ex-ante frameworks are now moving from proposal toward enacted law elsewhere, though at different speeds. Japan's Mobile Software Competition Act, passed in 2024, entered full enforcement in December 2025, requiring Apple and Google to permit third-party app stores and alternative in-app payment on their designated platforms. The UK's Digital Markets, Competition and Consumers Act 2024 took effect for digital markets in January 2025, giving the Competition and Markets Authority power to designate firms with "Strategic Market Status" — its first target, an investigation opened that same month, is Google's search business. Australia and South Korea are earlier in the process: both have ex-ante platform regimes under consultation or before their legislatures, not yet in force.
Why It Matters
For years, platform accountability ran mainly through competition law: regulators had to prove harm after it occurred, a process that could take a decade to resolve. What's spreading now is a different logic — designating platforms above a size threshold as gatekeepers and imposing operating obligations on them directly, ahead of any specific alleged harm. That converts what used to be a platform operator's unilateral design choices — who gets access, on what terms, to what data — into obligations that ecosystem participants can hold them to.
What This May Signal Next
The precedents being set in the EU's current enforcement actions, which cover app distribution, search, and messaging interoperability, are likely to influence how the newer regimes in Japan and the UK interpret their own obligations, and to shape the frameworks Australia and South Korea are still drafting. Ecosystem builders operating across multiple jurisdictions should expect the compliance landscape to keep diverging by region even as the underlying logic converges: large platforms are increasingly being regulated as designated infrastructure rather than as ordinary competitors.
6xD Lens
D1 — Digital Economy: platform markets are the dominant coordination mechanism for digital value creation, and this shift changes the terms on which value is captured and shared across an ecosystem. D3 — Digital Business Platforms: for any business built on top of a gatekeeper-designated platform, regulatory status is becoming a direct input to platform strategy, not a compliance afterthought.
Watch Next
Worth tracking which obligation categories — interoperability, data portability, algorithmic transparency — get tested first as Japan's and the UK's regimes move into active enforcement.
