Voices on the DMA: A Synthesis of the First Review Consultation

The European Commission’s public consultation on the first review of the Digital Markets Act (Article 53) ran to 24 September 2025, with a deadline tied to the Commission’s mandate to report by 3 May 2026. The Commission has now published the summary and individual contributions ↗: over 450 contributions in total, of which the public-version archive contains roughly 282 substantive responses (plus a handful of named submissions filed outside the survey form). This post is a synthesis of those submissions — who said what, what stood out, and where the consultation record is pulling the Commission as it drafts its report.

1. The overall gist

The respondents split, broadly, into four camps:

1. “DMA needs more teeth, faster.” Civil-society NGOs (BEUC, EDRi, FSFE, ARTICLE 19, CCDH, Open Markets Institute, Panoptykon, Homo Digitalis, Ius Omnibus, Balanced Economy Project, Bürgerbewegung Finanzwende), challenger platforms (Ecosia, DuckDuckGo, Mozilla, Aptoide, AltStore, F-Droid, Mastodon, Element/Matrix, Skyscanner, Kelkoo, idealo, Kieskeurig, Browser Choice Alliance, Coalition for App Fairness, Epic Games, EuroPA wallet alliance), European challengers in cloud and telecoms (OVHcloud, Clever Cloud, Telefónica, Deutsche Telekom, Orange, iliad, Vodafone, BEREC, GSMA + Connect Europe, Arcep), publisher coalitions (EPC, EMMA-ENPA, MVFP, News Media Europe, Finnmedia, DJV, EBU, DPCMO, Corint Media), and several national consumer organisations (DECO, UFC-Que Choisir, AK Wien, Euroconsumers). They share a frustration that gatekeepers are running rings around the Commission via “malicious compliance,” that fines are too small to deter, and that AI, cloud and connected-TV are slipping outside the DMA’s perimeter.

2. “Don’t reopen the DMA — and please walk it back.” Designated gatekeepers (Apple, Amazon, Meta, Alphabet, ByteDance/TikTok, Booking.com), and US-aligned trade groups (CCIA, Chamber of Progress, US Chamber of Commerce, NFTC, ITIF, ICLE, ABA Antitrust Section, SIIA, AmCham Ireland, AmCham Poland, Mercatus Center, ACT — The App Association, Digital Poland Association, Center for Cybersecurity Policy & Law, STRIDE-EUI, Esya Centre). The headline framings: DMA is causing user-experience harm, costing US firms billions, “discriminating against American innovation” (citing the February 2025 Trump White House directive on protecting US innovation), and chilling AI investment. Apple goes furthest of all and explicitly calls for the DMA to be repealed and replaced.

3. “Yes — but expand it carefully via delegated acts, not by reopening the legislation.” EU-aligned trade associations and federations (BEREC, DIGITALEUROPE, German Startup Association, Dutch Startup Association, Bitkom — divided internally, EuroCommerce, EU Travel Tech, EBF, Independent Retail Europe, FEDMA, France Digitale, Open-Xchange, Ecommerce Europe). They want the CPS list updated for AI and cloud, but through Article 19/3(8) market investigations and delegated acts — not a full legislative reopening, which they fear “would expose the EU to trade-related interference” (André Rebentisch’s phrasing).

4. Sectoral and niche submissions. Each demanding a specific tweak: PRIMET (weather services), AER (radio/Alexa), egta (broadcasters/AI Overviews), EUROCINEMA (SVOD/AVOD), IMPALA (TikTok–Merlin), the European Booksellers Federation, French Booksellers Union, Syndicat de la librairie française and book-trade respondents (Kindle/Amazon Marketplace), Goede Doelen Nederland (charity ad exemption), an anonymous Floriday-rival (sectoral horticulture platforms), MVNO Europe (eSIMs), Bizum/EMPSA/Fidesmo (NFC Secure Element), Hotelverband Deutschland + HOTREC + Visita (hotel direct-booking decline), Open Cloud Coalition + CISPE + CIO Platform Nederland (cloud designation), VAUNET + EBU (connected TVs), Verisure (alarms, AI), IFTAS + Social Web Foundation + Digital Public Goods Alliance (Fediverse interop).

The dominant cross-cutting theme is generative AI and cloud. Roughly two-thirds of all substantive submissions argue that AI assistants and LLMs (Gemini, ChatGPT, Meta AI, Copilot, Rufus, Grok, Claude, Perplexity) and hyperscale cloud (AWS, Azure, GCP, plus Microsoft Office 365 as enterprise-SaaS gateway) need to be added to the CPS list. The minority view, voiced almost exclusively by gatekeepers and US-funded trade groups, says AI is a competitive market that DMA would freeze. Underneath that is a sustained complaint about “compliance theater”: workshops, hundreds of meetings, and reams of compliance reports producing little real change in business-user conditions.

A second cross-cutting theme is enforcement procedure. Both sides want change — gatekeepers want hearing officers, oral hearings, file access, formal SOPs and cost-benefit analyses; complainants want binding investigation deadlines, interim measures (modelled on Reg. 1/2003 Art. 8), retaliation-proof whistleblower channels, structural remedies, director disqualification, fines moratoria off, and EU-level coordination with national authorities. A surprising number of respondents from both poles invoke the Draghi Report — each in their own service.

A third theme is geopolitics. Multiple respondents — France Digitale, French booksellers, Deutsche Telekom, an Italian news-app publisher, André Rebentisch, 1&1 Mail & Media, individual citizen Michael Bacq — explicitly warn the Commission against backing down under US tariff and Trump-administration pressure. The mirror-image arguments come from ITIF, NFTC, US Chamber of Commerce, SIIA, Digital Poland and the AmChams: the DMA is “discriminatory” and the US Government should be consulted before final measures.

2. Named respondents and their positions

Designated gatekeepers (and gatekeeper-side filings)

• Apple — calls for outright repeal, alleges DMA forced delays to Live Translation, iPhone Mirroring, Visited Places/Preferred Routes, AirPods translation, and “brought new categories of apps to iPhone — like pornography.” Apple wants Articles 5(4), 6(3), 6(7) “repealed or completely overhauled” and 6(4) overhauled. If not repealed, enforcement should be moved away from the Commission to “an independent European agency, shielded from political interference.”
• Amazon EU Sàrl — “DMA is one-size-fits-all”; cites AliExpress, Temu, Bol.com, Allegro, eMag as #1 in 13+ EU countries while not designated, calling treatment “discriminatory, arbitrary, biased.” Says Article 6(9) data portability creates security risks (75% of access requests come from non-EU applicants).
• Alphabet (Google) — wants the Commission to “remove the Sword of Damocles.” Cites 40+ submissions and 300+ meetings on Article 6(5) without resolution; says Article 5(2) consent UX work consumed ~3,000 engineers across two years; cites €4.4–€114bn estimated EU revenue loss.
• Meta Platforms Ireland — “600,000 engineering hours, equivalent to over six decades of work in less than two years” on DMA compliance. Cites 800% increase in ad dismissals after “Less Personalised Ads,” 70% drop in onsite conversion. Wants formal SOPs, audits, private “state of play” meetings instead of public workshops, and integration with the “Digital Simplification Package.”
• TikTok / ByteDance — opposes expansion, says cloud is B2B (so doesn’t fit DMA), AI is competitive, and that the UK DMCC’s tailored codes-of-conduct model would be preferable to one-size-fits-all. Notes “opportunistic misuse of the DMA” by complainants.
• Booking.com — opposes any new CPS categories (“regulatory creep”), questions the proposed DMA supervisory fee formula (“Amazon and X don’t pay because they don’t make profits”), defends qualitative-designation discretion.

Major business users, European challengers and SMEs

• Mozilla — “the DMA is working.” Browser choice screens doubled Firefox daily active users on iOS in the EU, +20% on Android, retention 5× higher than usual. Wants Microsoft Edge designated, faster non-compliance investigations, Article 13(4) anti-circumvention against the iOS browser-choice “hot seat.”
• DuckDuckGo — Google has “ignored or delayed” key obligations and circumvented others; estimates ≥30% of Android users haven’t seen choice screens; says Article 6(11) FRAND search-data terms exclude “north of 99%” of distinct queries; explicitly asks the Commission to open formal Art. 6(3) and 6(4) non-compliance proceedings against Google.
• Ecosia — claims gatekeepers are “dumping” AI-powered search by cross-subsidising it through Office suites. Wants Art. 6(3) non-compliance investigation and prescriptive Art. 46 implementing acts.
• Epic Games — fines alone are insufficient; “delay equals profits” (quoting US District Court v Apple); proposes EU could ban shipping non-compliant Apple products à la Common Charger Directive; wants criminal sanctions for repeat offenders, structural remedies, director disqualification, business-user collective redress under Art. 42.
• Coalition for App Fairness — extend Article 6(12) FRAND from app stores to operating systems; cites Epic’s US contempt-order victory as the model EU lacks.
• Aptoide — folder includes a months-long email exchange with Apple’s Vinay Reddy detailing post-January-2026 fee structures (17%+3%, 10%+3%, 5% Core Technology Commission for alternative marketplaces).
• AltStore — DMA “undeniably had a positive effect” (it enabled their EU launch); raises age-rating manipulation by Apple and rejection of JIT compilation interop on “non-technical grounds.”
• The App Fair Project — finds CPS designations “appropriate”; supportive of DMA scope as a non-profit app marketplace voice for app-store pluralism.
• Element / New Vector (Matrix) — wants Article 8(2) used to mandate open protocols; warns gatekeepers gate Art. 7 interop behind user-localisation requirements that conflict with GDPR data-minimisation; cites Bundeswehr, US Navy, Marines and NATO as Matrix users.
• F-Droid (Hans-Christoph Steiner) — Apple is exhibiting “malicious compliance from the beginning”; Google initially co-operated but “has shifted to Apple’s strategies of distraction and lock-in.” Worries DMA enabling only Epic Games Store would discredit alternative app stores generally.
• Mastodon gGmbH — extend Articles 6(9) and 7 to social networks; use Article 8 to require collectively-governed open protocols (ActivityPub).
• Skyscanner — Article 6(5) self-preferencing ban is the most important obligation; supports adding GenAI as a CPS via Article 19; warns DMA shouldn’t constrain much-smaller challengers (e.g., Bing) like the dominant provider.
• Kelkoo, Kieskeurig BV, idealo, Slevomat.cz, solute GmbH, Prisjakt, Fruugo (defending Google), Acheter-moins-cher — comparison-shopping cluster. Argue Google’s PLAs/Shopping Units exploit a definitional gap between “ranking” and “ad format” to recreate self-preferencing. Acheter-moins-cher writes in all caps: “OUR ORGANISATION DIE because neither the Shopping case nor 6.5 article of the DMA was enforce.”
• OVHcloud, Clever Cloud, Open Cloud Coalition, CISPE, OMI — cloud-side cluster. EU cloud share fell from 23% (2017) to 13% (2022), three US hyperscalers control 70%; CISPE: “AI will not run on the cloud — AI will be the cloud.” All call for cloud designation via Article 17.
• Deutsche Telekom, Orange, Telefónica, iliad, Vodafone, GSMA + Connect Europe (ETNO), MVNO Europe — telecoms cluster. Article 6(7) interop is “too narrowly conceived”; 5G network slicing is being blocked by Apple’s OS restrictions; iMessage opening “resulted from regulatory pressure, not voluntarism”; Apple’s iPhone Air eSIM-only push is framed by MVNO Europe as a human safety issue when 2G/3G fallback disappears. Vodafone praises the UK CMA’s flexible Conduct-Requirements model over DMA’s closed list.
• OnFabric — only submission with raw JSON dumps showing what gatekeeper data exports actually contain (TikTok exports give just “Date” and “Link”; Instagram ad-click data has no real product info; Meta’s recently_viewed_products returns stale data).
• Coalition for Online Data Empowerment (CODE) — granular API scorecard of each gatekeeper’s Art. 6(9) compliance; ByteDance API “very difficult to use,” Amazon verification took “two months with no communication,” Apple has verified only one CODE member, Meta export is “stripped of context, rendering it nearly useless.”
• PayPal — single-paragraph submission, the rare positive gatekeeper-business-user note: NFC opening enabled PayPal to launch its own NFC-enabled wallet in EEA.
• Bizum, EMPSA, Fidesmo — payments cluster. Apple has opened the Secure Element to developers in AU/BR/CA/JP/NZ/UK/US — but not the EU. Fidesmo: iOS 26 NFC AID-reading is “technically compliant” but unusable because users must manually enable each card.
• Trainline, Skyscanner, GetYourGuide, EU Travel Tech, Booking.com (designation context), Airlines for Europe — travel cluster split: airlines and regional aviation see Article 6(5) enforcement helping OTAs (Booking.com) at airline expense; aggregators are pushing harder for ranking neutrality.
• Independent Retail Europe, Otto Group, Ecommerce Europe, EuroCommerce, EUROCINEMA, IMPALA, European Booksellers Federation, Anitec-Assinform, Slevomat, Fruugo — retail and marketplace cluster. Otto warns AI agents will reduce retailers to “logistics providers.” IMPALA cites TikTok refusing to renew collective licensing with Merlin for indie labels as a concrete Art. 6(12) breach; complains the consultation form rejected its answer despite being under the 5,000-character limit.
• Mastodon, Element, IFTAS, Social Web Foundation, Digital Public Goods Alliance, Open-Xchange — federated/standards cluster. DPGA proposes new Article 6(9a) extending portability to social-graph and content; Open-Xchange laments that Gmail and Hotmail were not designated NIICS; Social Web Foundation transparently discloses Meta as a donor while advocating Fediverse interop.
• Verisure (alarms), QORIA (digital safety), Lovehoney (sex-toys e-commerce), an anonymous Floriday-rival (horticulture), Bürgerbewegung Finanzwende (financial services), Corint Media (German press collecting society), German cooperative banks (BVR), Federation of European Publishers — sectoral SMEs and trade bodies pushing for sector-specific tweaks.

Civil society and NGOs

• BEUC, Euroconsumers, UFC-Que Choisir, DECO, Altroconsumo, Test Achats, OCU, AK Wien, U.Di.Con., Homo Digitalis, Ius Omnibus — pan-EU and national consumer organisations. Common asks: designate consumer-facing cloud (iCloud, Google Drive), designate generative AI (Gemini, Meta AI, Copilot, Rufus, ChatGPT specifically), strengthen Article 5(8) tying ban (default iCloud, Meta AI in WhatsApp, Copilot in Microsoft 365, automatic Drive/YouTube account creation), allow OS use without forced sign-in. Euroconsumers proposes a strategic shift to horizontal interoperability obligations.
• EDRi + FSFE + Privacy International + Panoptykon — joint civil-society submission. Add GenAI and digital end-user devices (smart TVs, car infotainment) as new CPS layers; clarify “uninstall” = “delete”; ban gatekeeper notarisation/vetting fees on side-loaded apps; ban the €99/year Apple developer fee as a barrier to Art. 6(7) interop access.
• Center for Countering Digital Hate (CCDH), Open Markets Institute, Balanced Economy Project, ARTICLE 19, Project Liberty, Initiative for Neutral Search — anti-monopoly and digital-rights NGOs. Mostly favour CPS expansion; OMI proposes amending Annex E to swap “users” for “contracts” for cloud thresholds and add a general lock-in prohibition.
• Center for Cybersecurity Policy & Law (Venable-hosted, gatekeeper-funded) — security counter-narrative: warns Article 6(7) interop “disrupts established security models” of mobile OSes, expanding the attack surface and weakening supply chain.
• People vs Big Tech, Goede Doelen Nederland, Panoptykon Foundation — civil society. Goede Doelen Nederland is the only submission asking for a charity-specific exemption.
• Data Transfer Initiative (DTI) — civil society funded by Amazon, Apple, Google, Meta. Calls Article 6(9) the DMA’s “leading success story”; says virtual-assistants CPS already accommodates AI agents.
• Coalition for Open Digital Ecosystems (CODE) — Google and Meta are members (declared). Pushes against AI/cloud expansion but demands Apple’s iMessage, FaceTime and iCloud be designated. (A coalition that uniformly targets a single rival.)

Academics and think tanks

• Marc Bourreau & Jan Krämer (CERRE / Telecom Paris / Univ. Passau) — academic outlier. Calls for removing Article 7 entirely in a future revision: interoperability mandates deliver low contestability gains while raising security/privacy/enforcement costs. Strongly oppose extending Art. 7 to social networks. Recommend pivoting policy to promote multihoming (banning anti-multihoming dark patterns) instead.
• Alba Ribera Martínez (academic) — argues the Commission should not push KPI-based “metering” of contestability/fairness onto gatekeepers via compliance reports. Notes Art. 6(4) effects are underwhelming (fewer than 10 alternative app stores in EU); Art. 6(11) implementation is “disheartening.”
• Eckart Bueren (Göttingen) + Thomas Weck (Frankfurt School) — keep applying Article 102 TFEU alongside DMA; clarify that “online search engine” CPS covers AI-generated answers; cloud thresholds are poorly fit.
• SCiDA Research Team (Andriychuk, Podszun et al., Düsseldorf + Exeter) — independent academic 31-page paper, DFG/AHRC funded, structured across CPS list, designation, obligations, enforcement.
• Cristina Simone & Antonio Laudando (Sapienza) — DMA has theoretical “blind spots” failing to distinguish between sources (within vs between platforms) and types (monopolistic, Ricardian, Schumpeterian) of rents.
• Fair MusE / CEU (EU Horizon-funded) — wants Article 2(21) “business user” definition explicitly to cover music authors, performers, CMOs, IMEs, music publishers, record labels (post-ByteDance T-1077/23 ambiguity); change Art. 6(10) from “provided or generated” to “provided, generated or created.”
• ICLE (Manne, Auer, Radic, Ünekbas, Zúñiga) — gatekeeper-funded. Argues AI is “not a single, unitary technology”; lumping LLMs with computer vision and self-driving cars makes no analytical sense; DMA Art. 3(5) rebuttal standard violates legal-certainty principles per Case C-776/23 P.
• ITIF (Information Technology and Innovation Foundation) — explicitly cites the Trump White House’s February 2025 directive against unfair exploitation of US innovation; quotes MEP Andreas Schwab on the DMA being “designed to limit its scope to the top five American technology companies.”
• Mercatus Center (Alden Abbott, ex-FTC General Counsel; Satya Marar) — free-market critique; cites Taiwan FTC’s 2022 sceptical white paper.
• Esya Centre (India), STRIDE-EUI (India), American Bar Association (Antitrust + International) — outside-EU expert voices. Esya: CPS list “lacks consistent principle”; designation thresholds “vague, flawed, biased,” may breach WTO obligations. ABA: don’t single out AI in DMA; commission an independent third-party comparative review against UK CMA / German § 19a regimes for the 2029 review.
• Studienvereinigung Kartellrecht — 1,300+ German/Austrian/Swiss competition lawyers and economists; supports considering AI inclusion via Art. 19.
• Andreas Haupt (Stanford), Pieter Cleppe, Christophe Carugati, Milan Marićić, Preiskel & Co LLP, Linklaters, King & Spalding LLP, AEDC — academics and lawyers; commentary mostly favours guidelines, hearing officers, file-access rights and softer enforcement.

Regulators and authorities

• BEREC — strongly pro-DMA; calls for Article 7 to apply to communications “among users in general” (not just end users); offers BEREC and national regulators to assist Commission with data collection and review.
• Arcep (France) — calls for designating hyperscalers as gatekeepers via Article 17; wants Art. 6(12) FRAND access extended to cloud (incl. SaaS).
• Federal Competition Authority Austria (Bundeswettbewerbsbehörde) — pro-DMA, pro-enforcement perspective.
• Ministry of Consumer Protection Baden-Württemberg — calls for stronger self-preferencing ban extended to all CPSs incl. music streaming; faster enforcement; explicit rules for generative AI risks.

Trade associations (EU-side)

• DIGITALEUROPE, EuroCommerce, Bitkom, Anitec-Assinform, FEDIL, AMETIC, CCIA Europe, Chamber of Progress, Ibec, AmCham (Ireland and Poland), Digital Business Ireland, Digital Poland, Confederation of Swedish Enterprise, EU Travel Tech, Ecommerce Europe — generally caution against expansion. Bitkom unusually candid: “members are highly divided.” Anitec-Assinform claims compliance costs are “hundreds of millions per company” (vs the Commission’s €10–20M estimate). Digital Poland endorses CCIA’s $430M/firm/year compliance-cost estimate, calling for European Court of Auditors review.
• Coalition for App Fairness, Initiative for Neutral Search, Browser Choice Alliance, MVNO Europe, EuroPA wallet alliance, EMPSA, AER, EBU, egta, EUROCINEMA, IMPALA, Federation of European Publishers, EMMA-ENPA, MVFP, News Media Europe, EPC, Finnmedia, DJV, DPCMO, EBF, FEDMA, Alliance Digitale, ZAW, Union des marques, UDECAM, Audience Measurement Coalition (AMC), HOTREC, Hotelverband Deutschland, Visita, German Startup Association, Dutch Startup Association, Open Cloud Coalition, CISPE, CIO Platform Nederland (CIOPN), Beltug, EFAA, EGDF, France Digitale, Independent Retail Europe — generally pro-enforcement and pro-CPS-expansion (especially for AI and cloud).
• GSMA + Connect Europe, FEDMA, Audience Measurement Coalition, Alliance Digitale, ZAW — heaviest hitters in the ad-tech/transparency cluster; demand non-aggregated, event-level data under Article 6(8) and structural separation between buy-side and sell-side ad-tech.

Sectoral and single-issue specialists

• PRIMET (private weather services) — flags an entire industry (~3,000 staff, €400m sales) that the existing Apple/Google non-compliance proceedings explicitly don’t cover (those cover shopping/hotel/transport/finance/sport but not weather).
• EUROCINEMA, EBU, egta, VAUNET — broadcasters/audiovisual: extend OS designation to Android TV / connected TVs, designate Virtual Assistants, treat AI Overviews/AI Mode as CPSs.
• Japan Association of New Economy (JANE) — coined the framings “malicious compliance” and AI “execution by default”; recommends adding data scientists and AI engineers to the Commission enforcement team.

Individuals and personal-capacity submissions

A long tail of named individuals — Atif Unaldi, Christian Brüggemann, Cecile Tonglet, Pieter Cleppe, Albertino Stacchiotti, Hans-Joachim Gille, Maria Donati, Séverin Lemaignan, Henrik Stougaard, Stanisław Dobrowolski, Echedelle López Romero, Steli Andrei, David Governo, André Rebentisch, Michael Bacq, Andreas Haupt, Eugenio Diaz Sánchez — and many more anonymised. Their themes cluster around: macOS, Xbox and PlayStation as missing CPSs; Cloudflare as a hidden gatekeeper; sideloading and JIT compilation rights; opposition to the DMA from a libertarian perspective; and warnings against the EU caving to Trump-administration tariff pressure.

3. Notable tidbits

• Apple wants the DMA repealed — by far the most extreme position from any gatekeeper. Among Apple’s grievances: that DMA “brought new categories of apps to iPhone — like pornography” and “opened the door wider for scams and malware.”
• Mozilla’s evidence the DMA works: browser choice screens doubled Firefox daily active users on iOS in the EU; +20% on Android, retention 5× normal. PayPal similarly cites NFC opening as a positive concrete win.
• Meta’s “six decades of engineering work”: 600,000 hours on DMA compliance in under two years, “equally to over six decades worth of engineering work.”
• Aptoide’s leaked correspondence with Apple’s Vinay Reddy publicly documents the post-January-2026 fee structures (17%+3%, 10%+3%, 5% CTC).
• CCIA’s “independent” study is funded by CCIA — King & Spalding’s 33-page paper, filed via Chamber of Progress (which discloses gatekeeper funding), is a rare textbook example of a coordinated pro-gatekeeper narrative dressed up as legal research.
• CISPE’s framing: “AI will not run on the cloud — AI will be the cloud.”
• Ecosia accuses gatekeepers of dumping: “Developing AI-powered search is extremely costly, yet gatekeepers provide these capabilities for no extra cost, as part of their office suites.”
• Apple’s Secure Element: opened to developers in AU/BR/CA/JP/NZ/UK/US — but not the EU — even though the DMA was supposed to be the strongest pro-interoperability law in the world. (Bizum, EMPSA, Fidesmo all note this.)
• An anonymous SME describes Apple’s €1,000,000 standby letter of credit (from an A-rated financial institution) requirement to operate an alternative iOS marketplace as effectively SME-prohibitive.
• An anonymous Apple developer describes attending Apple’s June 2025 Brussels DMA workshop, exchanging cards with VP Kyle Andeer, being told “we need to talk” — and never receiving a follow-up.
• MVNO Europe frames Apple’s eSIM-only iPhone Air rollout as a human safety risk, since VoLTE access becomes essential as 2G/3G are sunset.
• DuckDuckGo says Google’s Article 6(11) FRAND search-data terms exclude “north of 99% of distinct queries” and explicitly asks the Commission to open formal Art. 6(3)/6(4) non-compliance proceedings.
• PRIMET flags that the Apple/Google non-compliance proceedings don’t cover weather services — an entire pan-European industry feels existentially threatened by Apple’s pre-installed Weather app and Google’s Weather OneBox.
• Acheter-moins-cher (in all caps): “OUR ORGANISATION DIE because neither the Shopping case nor 6.5 article of the DMA was enforce.”
• Hans-Joachim Gille (German citizen) wins the prize for most extreme anti-DMA submission: tells the Commission to face a “court-marshall, a Nuremberg 2.0” and to “Stop this Stalinistic bullshit.”
• Popescu Lavinia (Romania) filed an SME submission with placeholder text “Kdxjhsjshsjhs”, “Hsyzksysmsb”, “Gggfgfgt” in transparency-register fields — an apparent error/junk entry now permanently on the public record.
• Steli Andrei (Romania) ticked “Gatekeeper” as their respondent type with affiliation “Mehadia” (a small Romanian town) — almost certainly a misclassification.
• EUROCINEMA recycled a 2023 position paper rather than writing a fresh 2025 one — its concerns about Amazon/Apple ancillary streaming leverage are essentially the original DMA-negotiation arguments.
• André Rebentisch accuses the Commission of “fraternisation” with non-European lobby groups and warns reopening DMA in current geopolitics risks “trade-related interference” (implicit Trump reference).
• France Digitale, French booksellers, Deutsche Telekom, an anonymous news-app publisher all explicitly tell the Commission not to back down on enforcement under US tariff pressure.
• NFTC mirror-images this by asking the Commission to “consult with the U.S. government before adopting final measures.”
• ITIF quotes the Trump White House’s February 2025 directive on protecting US innovation, and MEP Schwab admitting the DMA was “designed to limit its scope to the top five American technology companies.”
• HOTREC and ZPP (Poland) flag a “one gatekeeper replacing another” pattern: forcing Google to scale back self-preferencing has boosted Booking.com at independent hotels’ expense. ZPP cites Polish hospitality SMEs seeing a 30% drop in direct bookings post-Article 6(5) enforcement.
• OnFabric’s raw JSON dumps are the only submission where a respondent literally pastes broken portability output into the consultation.
• Open-Xchange quotes a personal blog post titled “after-self-hosting-my-email-for-twenty-three-years-i-have-thrown-in-the-towel-the-oligopoly-has-won” as substantive evidence.
• Bourreau & Krämer (CERRE) — call to delete Article 7 entirely is the most striking academic dissent in the corpus.
• CCIA’s evidence base: cites a 5,000-consumer 20-country survey claiming 67% of consumers say search now takes longer; €71B aggregate compliance cost estimate; €4.4–€114bn projected EU revenue loss.
• IMPALA’s Merlin example: TikTok refused to renew collective licensing through Merlin (digital rights agency for indie labels) and offered “take-it-or-leave-it” individual deals — used as a concrete Article 6(12) breach.
• The Coalition for Open Digital Ecosystems (CODE) has Google and Meta as members and uses the consultation to argue against AI/cloud expansion while demanding Apple’s iMessage, FaceTime and iCloud be designated. A coalition that uniformly targets a single rival.
• An anonymous Dutch SME is the only submission arguing for sectoral gatekeeper designation (industry-specific platforms like Floriday in horticulture) rather than horizontal scale-based designation.
• JANE (Japan) introduces the term “malicious compliance” and AI “execution by default” — useful coinages now widely echoed in the consultation.
• Project Liberty cites US “Digital Choice Act” (Utah, 2025) as an EU precedent — interesting transatlantic policy diffusion in the opposite direction from usual US-criticises-EU framing.
• Browser Choice Alliance publicly backs Opera’s General Court challenge (T-357/24) to the Commission’s 2024 decision NOT to designate Microsoft Edge — pointing the Commission’s review at one of its own decisions already under judicial review.
• The Commission’s own consultation form rejected IMPALA’s submission despite being under the 5,000-character limit, forcing the trade body to upload it as an attachment — a small but telling friction at the Commission’s own door.
• A duplicate “ACT”: the Commission received submissions from two unrelated organisations called ACT — “ACT — The App Association” (US-aligned, gatekeeper-donor-funded SME app developer group) and “ACT — Association of Commercial Television and VOD in Europe” (Belgian broadcaster trade body) — taking opposite positions on AI as CPS.

4. Bottom line

The first DMA review consultation has produced a strikingly polarised record. On one side, designated gatekeepers and US-aligned trade bodies argue the DMA is causing tangible harm (delayed features, compliance cost, trade friction) and the Commission should narrow it, hand enforcement to an independent agency, or — in Apple’s case — repeal it. On the other side, European challengers, civil-society NGOs, national consumer organisations, regulators, sectoral business users and most academics argue the DMA is under-enforced, that gatekeepers are running a “compliance theater” of workshops and reports, that fines are too small to deter, and that AI assistants and cloud infrastructure are now the dominant gatekeeping vectors and must be brought into scope. Procedurally, both sides agree the current process is broken — but they disagree sharply on the fix. Geopolitically, the consultation is unmistakably shaped by US tariff pressure and the Trump-administration directive, with European respondents repeatedly warning the Commission not to fold and US respondents demanding the Commission consult Washington first.

The sharpest signal in the corpus is the near-unanimity of business-user, SME, regulator and civil-society respondents that generative AI and hyperscale cloud must be designated — typically through Article 17/19 market investigations and delegated acts, not by reopening the DMA legislation itself. That is the operational question the Commission’s report by 3 May 2026 will need to answer.