The European Commission’s (“Commission”) enforcement of the Digital Markets Act (“DMA”) has progressed steadily since its entry into force late 2022. Public enforcement of the DMA has entered a phase where compliance-related activity is becoming more frequent and more complex. The Commission continues to assess which providers of a core platform service (“CPS”) should fall within the scope of the DMA, so far having resulted in the designation of seven undertakings as gatekeepers for various CPS. Alongside these designation decisions, the Commission also issued several decisions in which it identified services as CPS, but in which it ultimately decided to not designate the provider of the CPS in question as a gatekeeper (“non-designation decisions”).

Beyond designation and non-designation decisions, the Commission has increasingly focused on gatekeepers’ compliance with the DMA’s obligations and the measures these gatekeepers ought to take in that regard. This has led to a growing number of parallel investigations, non-compliance decisions and specification decisions, each addressing different aspects and obligations of the DMA. Many of the Commission’s decisions have furthermore been appealed and now sit at different stages of the judicial process – some pending before the General Court, others having already proceeded to the Court of Justice.

As the enforcement and appeal processes multiply, it has become more challenging for practitioners and other stakeholders to maintain a clear overview of the DMA’s “state of play”. In earlier blogs we have already paid attention to the DMA’s general mechanisms, its obligations and the potential for private enforcement. In this blog, we aim to provide you with a structured visual overview of the Commission’s actions to date, through a series of slides that summarise the key decisions and situate them within the broader procedural landscape.

Last updated: 3 December 2025