DMA obligations

The Digital Markets Act (DMA) obligations are specific duties that "gatekeepers" – large digital platforms with significant market power – must follow to ensure fair and contestable digital markets in the EU. These obligations prevent anti-competitive practices, protect business users and consumers, and promote innovation across the digital sector.

Legal Basis

"Gatekeepers shall comply with the obligations set out in Articles 5, 6 and 7 of this Regulation in respect of each of their core platform services listed in the designation decision."

— Article 3, Regulation (EU) 2022/1925 (Digital Markets Act)

Why It Matters

DMA obligations affect the largest digital platforms operating in the EU, including major search engines, social networks, messaging services, and online marketplaces. When a platform is designated as a gatekeeper, it must immediately comply with obligations designed to prevent unfair practices such as self-preferencing, data combination without consent, and restricting users from uninstalling pre-installed apps.

These obligations matter for political advertising publishers and platforms because many VLOPs (Very Large Online Platforms) that publish political ads are also gatekeepers under the DMA. The obligations shape how these platforms can use data, rank content, and interact with business users – including political advertisers and campaigns. For example, DMA rules on data combination and transparency directly impact how platforms can target political ads and what information they must provide to advertisers.

Understanding DMA obligations helps political actors, publishers, and compliance teams navigate the intersection of competition law, platform regulation, and political advertising transparency rules under the TTPA.

Key Points

Gatekeeper designation: Only platforms meeting specific thresholds (significant EU turnover or market cap, 45+ million monthly active EU users, 10,000+ yearly business users) are designated as gatekeepers and must comply with DMA obligations
Three tiers of obligations: Article 5 obligations apply immediately and always; Article 6 obligations may be specified further by the Commission; Article 7 applies to emerging gatekeepers
Core prohibitions: Gatekeepers cannot combine personal data without consent, cannot favor their own services over competitors (self-preferencing), and cannot restrict users from switching services or uninstalling apps
Transparency requirements: Gatekeepers must provide advertisers and publishers with access to performance measuring tools and information necessary for ad inventory verification
Enforcement and fines: The European Commission enforces DMA obligations directly, with fines up to 10% of global annual turnover (20% for repeated infringements)
Overlap with TTPA: Many VLOPs subject to political advertising transparency rules are also DMA gatekeepers, creating overlapping compliance obligations for political ad publishers

DMA Obligations vs. TTPA Obligations

DMA obligations apply to designated gatekeepers across all their core platform services and focus on preventing anti-competitive practices and ensuring fair, contestable markets. TTPA obligations apply specifically to political advertising and focus on transparency, labeling, and restrictions on targeting techniques using personal data.

Key differences:

Aspect	DMA Obligations	TTPA Obligations
Scope	All core platform services of gatekeepers	Political advertising only
Primary goal	Fair competition and contestability	Transparency and electoral integrity
Who must comply	Designated gatekeepers only	All political ad publishers and sponsors
Main focus	Business practices, data use, interoperability	Ad labeling, transparency notices, targeting limits

While separate regulations, both can apply simultaneously to large platforms that publish political ads and are designated as gatekeepers.

Related Terms

Very transparent. Every political ad will be labelled, linked to a transparency notice with detailed information, and online ads will be searchable in a central European repository.

The Network coordinates election-related cooperation between member states. National contact points for TTPA enforcement should be members of this network where possible.

Election campaigns will need to ensure all paid advertising includes proper labels and transparency notices. Sponsors must be prepared to provide required information to all service providers.

Several major platforms currently do not allow paid political advertising, including some large social networks. This limits where political actors can place paid online advertisements.

The TTPA applies from 10 October 2025. Member States had until 10 April 2025 to designate competent authorities, and the Commission must provide label templates by 10 July 2025.

Publishers must ensure completeness and accuracy of certain information but are not required to verify all sponsor claims. They must correct manifestly erroneous information when they become aware of it.

Yes. When a hosting provider and a website both display an ad, both are considered publishers with responsibility for their specific services. Contracts should clarify how they share compliance duties.

If a publisher removes or disables access to a political ad due to illegality or terms violations, they must still provide access to the transparency information for the full seven-year retention period.