The Clock That Started in September 2022
The Digital Markets Act entered into force on 1 November 2022, but the regulation built in a lag: obligations would not bite until gatekeepers had been formally designated and given six months to comply. The European Commission opened designation proceedings in May 2023, and by September of that year it had issued the first formal decisions. Six companies received gatekeeper status covering a total of twenty-two core platform services: Alphabet, Amazon, Apple, ByteDance, Meta, and Microsoft. The six-month compliance clock began running from those September decisions, which placed the hard deadline on 7 March 2024.
That morning, Article 5 and Article 6 obligations under the Digital Markets Act ↗ became enforceable across the designated services. Non-compliance carries fines of up to 10 percent of global annual turnover, rising to 20 percent for repeat violations. Systematic infringement can trigger a market investigation and, ultimately, structural remedies.
What Changed for Apple and Google
Apple's gatekeeper designation covered the iOS operating system, the App Store, and Safari. The obligations that took effect on 7 March 2024 required Apple to allow alternative app marketplaces and sideloading on iOS within the EU — a requirement that had been structurally impossible under Apple's prior rules. Developers gained the right to use third-party payment processors inside their apps without routing transactions through Apple's in-app purchase system, and the anti-steering prohibition that had prevented developers from telling users about cheaper options elsewhere was no longer permitted.
Apple published its DMA compliance plan in January 2024, roughly six weeks before the deadline. The plan introduced what the company called a new business terms option for EU developers, carrying a reduced commission but adding the Core Technology Fee of €0.50 per install beyond one million annually. It also introduced a notarisation requirement for apps distributed outside the App Store — a mandatory automated security review that apps must pass before EU devices will install them. Both the fee structure and the notarisation requirement drew immediate criticism from developers and scrutiny from the Commission.
Chronology
- 1 November 2022Digital Markets Act enters into force
- May 2023Commission opens gatekeeper designation proceedings
- September 2023Six gatekeeper designation decisions issued; six-month compliance clock begins
- January 2024Apple publishes DMA compliance plan, including Core Technology Fee and notarisation requirement
- 7 March 2024Article 5 and Article 6 obligations become enforceable
- March 2024Commission opens proceedings on Apple interoperability, browser choice, and fee structure
- April 2025First DMA enforcement fine (€500 million, against Apple)
For Google, the designated services included Google Search, Google Play, Android, Chrome, Google Maps, Google Shopping, YouTube, and Google Ads. The 7 March obligations required Google to allow third-party payment systems on Google Play in the EU and to permit sideloading — Android had already permitted the latter by default, meaning the practical change was narrower than for Apple. Google was also required to give users a genuine choice of default search engine and browser during device setup, and to stop privileging its own services in Search results rankings.
A Deadline, Not an Endpoint
The Commission had made clear that designation and the compliance deadline were the start of enforcement, not its conclusion. Several opened investigations followed within weeks and months of 7 March. In March 2024 the Commission launched proceedings examining whether Apple's interoperability rules, its browser choice implementation, and its new fee structure actually satisfied the regulation's requirements. The April 2025 fine of €500 million against Apple — the first DMA enforcement penalty — arose directly from non-compliance findings related to anti-steering obligations that should have been met from the moment obligations became enforceable on that date.
The six gatekeeper designations in September 2023 did not cover every large platform service in scope; the Commission indicated further designations could follow as other services met the thresholds under Article 3. But for the companies designated by that first round, 7 March 2024 ↗ marked the moment the DMA moved from an anticipated framework to a set of legally binding daily obligations with a credible enforcement mechanism behind them.
