Gatekeeper

A gatekeeper is a large digital platform provider designated by the European Commission under the Digital Markets Act (DMA) because of its significant impact on the internal market, its role as an important gateway for business users to reach end users, and its entrenched and durable position. Gatekeepers must follow strict rules to ensure contestable and fair digital markets in the EU.

Legal Basis

"An undertaking providing core platform services that meets three criteria: (1) significant impact on the internal market, (2) acts as an important gateway for business users to reach end users, (3) enjoys an entrenched and durable position (or will foreseeably do so). Designated by the Commission."

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

Why It Matters

Gatekeepers are the largest and most influential digital platforms in Europe—companies like Google, Meta, Apple, Amazon, and Microsoft. Because of their size and central role in how people access information and services online, they can shape entire markets and determine whether smaller businesses succeed or fail. The DMA designation comes with significant legal obligations designed to prevent these platforms from abusing their market power.

For businesses advertising online, including those running political advertising campaigns, gatekeeper platforms are often unavoidable channels to reach audiences. This is why the DMA imposes obligations such as prohibiting self-preferencing, requiring interoperability, and ensuring business users can access their own data. For political advertising specifically, gatekeepers designated as Very Large Online Platforms (VLOPs) under the Digital Services Act face additional transparency and risk mitigation requirements, especially around elections.

Understanding gatekeeper status helps businesses and political actors know which platforms face the strictest EU oversight and which obligations apply to their advertising activities. It also explains why certain platforms must comply with heightened transparency rules under both the DMA and related regulations like the TTPA.

Key Points

Gatekeepers are designated based on quantitative thresholds: €7.5 billion annual EU turnover or €75 billion market capitalisation, plus at least 45 million monthly active EU end users and 10,000 yearly active EU business users
The Commission can also designate gatekeepers qualitatively if they meet the three core criteria even without hitting all thresholds
Core platform services covered include online search engines, social networks, video-sharing platforms, messaging services, operating systems, web browsers, cloud computing, and online advertising services
Gatekeepers must allow business users to promote offers outside the platform, allow users to uninstall pre-installed apps, provide data portability, and refrain from combining personal data without consent
Violations can result in fines up to 10% of global annual turnover (20% for repeated infringements)
Many gatekeepers are also designated as VLOPs or VLOSEs under the Digital Services Act, triggering additional election-related obligations

Gatekeeper vs. Very Large Online Platform (VLOP)

While both terms describe major digital platforms under EU regulation, they come from different laws with different purposes. A gatekeeper is designated under the Digital Markets Act (DMA) to address market power and ensure fair competition. The focus is on preventing anti-competitive practices like self-preferencing and tying services together.

A Very Large Online Platform (VLOP) is designated under the Digital Services Act (DSA) based on reaching 45 million monthly active users in the EU. The VLOP designation focuses on systemic risks from illegal content, disinformation, and threats to civic discourse and elections. VLOPs must conduct risk assessments and implement mitigation measures, including specific protections around electoral processes.

Many of the same companies are designated as both gatekeepers and VLOPs—for example, Meta's Facebook and Instagram, Google's Search and YouTube, and TikTok. However, the obligations differ: DMA obligations focus on market fairness and competition, while DSA obligations focus on content moderation, transparency, and protecting democratic processes. For political advertising, this means designated platforms may face obligations under both the DMA, the DSA, and the TTPA (Regulation 2024/900).

Related Terms

Very Large Online Platform (VLOP)
Core Platform Service
Digital Markets Act (DMA)
Digital Services Act (DSA)
Provider of Political Advertising Services
Publisher
Targeting Techniques
Online Platform
Transparency Notice
Systemic Risk

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.