The European Union has made no secret of its desire to be the world’s “digital regulator” and it has had some success. CEPA’s new project, “Mapping the Brussels Effect,” shows the spread of the EU’s tech regulations across the world. The map shows that there is an appetite for digital rules in many nations outside the EU.

The first map illustrates the spread of the Digital Markets Act (DMA) across the globe, highlighting countries at different stages of adoption, from initial discussions to fully enacted legislation.

CEPA’s DMA map aims to help researchers and policymakers understand the scope of the EU’s global regulatory footprint. It will be updated on a quarterly basis. New maps are under preparation for other key European digital regulations, such as the Digital Services Act and the General Data Protection Regulation. The data are compiled from legal publications, reliable reportage, and source documents. If you see something about which you would like to inform us, please email TechPol@cepa.org.

The Digital Markets Act

What is it?

The DMA is a European competition law. Its goal is to spark competition in markets dominated by Silicon Valley giants.1 The act targets six “gatekeepers”: Alphabet (Google), Amazon, Apple, ByteDance, Meta, and Microsoft, aiming to reshape app stores, online advertising, e-commerce, messaging services, and other digital tools. In the view of European regulators, these giant technology firms have generated enormous growth and innovation — but they also dominate digital markets and squeeze competition.

Photo: App Store icon displayed on a phone screen is seen in this illustration photo taken in Krakow, Poland on August 6, 2023. Credit: Jakub Porzycki/NurPhoto
Photo: App Store icon displayed on a phone screen is seen in this illustration photo taken in Krakow, Poland on August 6, 2023. Credit: Jakub Porzycki/NurPhoto

Why Does it Matter?

The DMA introduces ex ante, or “before the fact,” rules for companies to follow. The European Commission no longer has to wait for a breach of the rules to occur before making its case but rather can insist that companies prove how compliance will happen. So, for example, Apple and Google must allow more interoperability for devices.

The stakes are high. Many countries beyond Europe share similar views on regulating Big Tech. Japan and the United Kingdom (UK), among others, have already adopted similar rules and several larger countries including India and Brazil are actively considering following suit.

Countries

Australia

DMA Status: Early discussion of new rules

Australia is considering ex ante competition regulations similar in nature to those in the Digital Markets Act.2 3 The Australian Competition and Consumer Commission has released its final report on the Digital Platform Services Inquiry.4 Its recommendations include rules on self-preferencing, bundling, and interoperability plus gatekeeper-level designation.

Brazil 

DMA Status: Similar rules proposed

The Brazilian Parliament is considering PL 2768/2022, which would create competition regulations for digital platforms.5 The bill would designate platforms that generate an annual revenue of at least US$32 million as “essential access control power holders,” similar to the gatekeeper designation.6 The bill lacks a definition for “fair competition” but would give the government the power to impose fines of up to 2% of the total national revenue on any platform that violates its regulations.7 US tech advocates have expressed strong opposition.8 Following a public comment period in 2024, Brazil is revising its framework, with a new proposal expected in early 2025.

Photo: Woman consulting her smartphone listening to music or podcasts with headphones in the an aerial metro train TTC (Toronto Transit Commission) of Toronto Canada s economic capital in the province of Ontario on 20 April 2023. Credit: Reuters.
Photo: Woman consulting her smartphone listening to music or podcasts with headphones in the an aerial metro train TTC (Toronto Transit Commission) of Toronto Canada s economic capital in the province of Ontario on 20 April 2023. Credit: Reuters.

Canada 

DMA Status: Similar rules proposed

Canada’s Competition Bureau submitted comments with its recommended reforms to the country’s Competition Bill in 2022, with language and proposals mirroring the Digital Markets Act.9 Similar to the gatekeeper designation, the reforms call for regulating “digital giants,” described as having a high degree of influence in various sectors of the economy. The proposal primarily regulates mergers among digital companies, calling for longer limitation periods and more reporting mechanisms so that the commission would be notified about mergers by digital giants. 

China 

DMA Status: None

Chinese authorities have launched an antitrust crackdown targeting major tech companies, amending the country’s Anti-Monopoly Law accordingly.10 11 As major Chinese tech companies are subject to government control and the Chinese Communist Party supports the creation of global leaders in tech, the rule changes should be treated with skepticism.12

Photo: European Commission President Ursula von der Leyen and European Council President Charles Michel (not pictured) attend a news conference following a virtual summit with Chinese President Xi Jinping in Brussels, Belgium June 22, 2020. Credit: REUTERS/Yves Herman/Pool
Photo: European Commission President Ursula von der Leyen and European Council President Charles Michel (not pictured) attend a news conference following a virtual summit with Chinese President Xi Jinping in Brussels, Belgium June 22, 2020. Credit: REUTERS/Yves Herman/Pool

European Union

DMA Status: Digital Markets Act applies

All European Union members are subject to the Digital Markets Act.

Iceland

DMA Status: Digital Markets Act applies

As a member of the European Free Trade Area, Iceland is subject to the Digital Markets Act.

India

DMA Status: Similar rules proposed

India’s revised draft Digital Competition Bill, proposed in 2024 by the Ministry of Corporate Affairs, identifies “Systematically Significant Digital Enterprises.”13 Firms included have over 10,000 users and a financial threshold of US$480 million, global turnover of at least $30 billion, gross merchandise value in India of at least $1.9 billion, or global market capitalization of at least $75 billion.14 The bill directly targets online search engines and digital platforms, and like the Digital Markets Act, limits self-preferencing and requires marketplaces to permit access for third-party apps.

Indonesia 

DMA Status: Early discussion of new rules

The ministry has discussed rules for regulating digital platforms, explicitly referencing both the Digital Markets Act and Digital Services Act.15

Japan

DMA Status: Similar rules adopted

Japan has implemented a DMA equivalent through its Smartphone Software Competition Promotion Act (SSCP), passed by the Japanese Diet in June 2024.16 The Japanese rules are narrower than DMA, and target at this point only two companies, Google and Apple, and two use cases, interoperability and app stores. The government is now working up guidelines about how to enforce the rules, which are expected before the end of the year.

Photo: Teresa RIBERA RODRÍGUEZ (Third Deputy Prime Minister and Minister for the Ecological Transition and the Demographic Challenge, Spain) Credit: @Teresaribera via Twitter https://x.com/Teresaribera/status/1795442791532925369/photo/1
Photo: Teresa RIBERA RODRÍGUEZ (Third Deputy Prime Minister and Minister for the Ecological Transition and the Demographic Challenge, Spain) Credit: @Teresaribera via Twitter https://x.com/Teresaribera/status/1795442791532925369/photo/1

Kazakhstan

DMA Status: Similar rules adopted

Kazakhstan recently passed the Law on Internet Advertising and Online Platforms, which contains elements regulating how digital platforms can operate in the country, including a ban on user profiling and reporting requirements depending on the size of the user base.17 18 The more far-reaching elements of the Digital Markets Act are missing.

Kenya

DMA Status: Similar rules proposed

Kenya proposed legislation targeting digital platform competition including a gatekeeper-like designation. In June 11, 2024, the government closed a comment period on the amendment to the Competition Bill, which includes provisions addressing anti-competitive behavior in digital markets.19 Regional organizations such as the Common Market for Eastern and Southern Africa and the African Continental Free Trade Area are also considering similar competition proposals.20

Liechtenstein

DMA Status: Digital Markets Act applies

As a member of the European Free Trade Area, Liechtenstein is subject to the Digital Markets Act.

Malaysia

DMA Status: Early discussion of new rules

In August 2024, the Malaysia Competition Commission announced a market review of the impacts of the digital economy ecosystem.21 22 While the market review is still underway, it targets many of the same large tech firms listed in the Digital Markets Act, namely digital platforms serving consumers directly, digital advertising companies, and search engine operators.23 The market review will also assess new restrictions and reporting requirements for mergers between technology companies. 

A lady seen passing by the Samsung company advertisement at TRX exchange, Kuala Lumpur. Brand and logo at Kuala Lumpur city.

Mexico

DMA Status: Similar rules proposed  

In February 2024, Mexico’s Federal Economic Competition Commission published a report outlining the state of competition in e-commerce markets — a narrower scope than the Digital Markets Act.24 The report concluded that there is no “effective competition” as, together, Amazon and Mercado Libre have an 85% market share.25 The report proposes policies to tackle barriers to entry for newcomers.26 While the report is not an act of parliament, it does direct government agencies within the Mexican executive to implement its orders, such as limitations on self-preferencing, transparency requirements as to providers and downstream operators, and limits on the use of premium membership. 

Morocco

DMA Status: Early discussions of new rules

Senior officials in Morocco’s High Authority for Audiovisual Communication have made statements hinting at upcoming digital regulations that could mirror the Digital Markets Act.27 The head of the agency stated, “Morocco, as other African countries, is making sustained efforts to build a regulatory capacity capable of framing the various dimensions of Big Tech’s actions.” Officials have yet to share any details about those efforts.

New Zealand

DMA Status: Early discussion of new rules

On December 5, 2024, the Ministry of Business, Innovation and Employment of New Zealand unveiled a discussion paper on “‘Promoting competition in New Zealand – A targeted review of the Commerce Act 1986,” with new antitrust rules.28 While this report is not an act of parliament or executive order, it points to the future direction of incoming legislation, particularly when it comes to protecting competition in digital markets.29

Nigeria

DMA Status: Similar rules adopted

In January 2022, Nigerian regulators amended the 2018 Federal Competition and Consumer Protection Act with new regulations to target data access and the digital economy.30 31 This amendment includes sections on self-preferencing, market capitalization, and other perceived anti-competitive behaviors.    

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Norway

DMA Status: Digital Markets Act applies

As a member of the European Free Trade Area, Norway is subject to the Digital Markets Act.

South Africa

DMA Status: Early discussion of new rules

South Africa’s Online Intermediation Platforms Market Inquiry recommended changes to the Competition Act, including ex ante regulations.32 The report included references to the Digital Markets Act.

South Korea

DMA Status: Similar rules proposed

The Korea Fair Trade Commission introduced an amendment to the Fair Trade Act on October 28, 2024, to the National Assembly.33 The bill, which resembles the Digital Markets Act with a ban on self-preferencing and the creation of monetary thresholds for “dominant online platforms,” places rules on mergers and introduces new reporting requirements.34 The new act was a response to the Republic of Korea Democratic party’s draft Platform Competition Promotion Act, from December 2023, which aimed to curb anti-competitive behaviors, including self-preferencing and bundling. The legislation lists homegrown firms Naver and Kakao as in scope.35 There have been previous attempts to introduce ex ante rules for digital players including efforts to prevent large platforms from forcing the use of in-app payment systems but after backlash from South Korean industry and the US government, those plans were halted.36

Photo: A woman wearing a protective mask walks past an iPhone 12 advertisement in Seoul. Credit: Photo by Simon Shin / SOPA Images/Sipa USA
Photo: A woman wearing a protective mask walks past an iPhone 12 advertisement in Seoul. Credit: Photo by Simon Shin / SOPA Images/Sipa USA

Switzerland

DMA Status: Not to date

Switzerland has a series of bilateral agreements with the EU to ensure access to the European single market. The Digital Markets Act has not been included in these agreements. The Swiss Interdepartmental Coordination Group on EU Digital Policy conducted a months-long analysis of the impact of the EU’s regulatory initiatives on Switzerland and its markets.37 The analysis results released in April 2023 found no immediate need for Swiss action on the Digital Markets Act as the prevailing EU approach did not present any significant access barriers for the Swiss digital market.38 A further review is expected by the end of 2024. 

Thailand

DMA Status: Similar rules proposed

In January 2024, Thailand released a draft of the Platform Economy Act, which mirrors the DMA’s gatekeeper designation and would require additional reporting from platforms with more than US$2.8 million in annual revenue or more than 10,000 monthly Thai users. Critics worry this law would impact business-to-business operations for smaller firms down the pipeline.39 In response to this criticism, in May 2024 the Electronic Transactions Development Agency tasked the Thailand Development Research Institute with conducting a legal impact assessment of the draft act.4041

Turkey 

DMA Status: Early discussion of new rules

The Turkish Draft Regulation on Amending Law on the Protection of Competition has been under consideration since June 2024.42 Both the Turkish Competition Authority and industry stakeholders have been actively involved in consultations, with a focus on regulating perceived anti-competitive practices by dominant digital platforms.43 The government aims to finalize the draft and introduce it to parliament in 2025.

United Kingdom

DMA Status: Similar rules adopted

On September 19, 2024, the United Kingdom enacted the Digital Markets, Competition and Consumers Act, which aims to create rules for large digital platforms.44 The act is, in effect, a more flexible version of the Digital Markets Act — giving enforcers greater discretion to narrow or expand the breadth of investigations on a case-by-case basis. A new unit in the UK’s Competition and Markets Authority (CMA) now administers ex ante rules for firms with “strategic market status.” The CMA can determine which firms fit that designation on a case-by-case basis and impacted firms must follow “conduct requirements” as prescribed by the CMA. The CMA was also given fining powers of up to 10% of global revenues, or 20% for repeat offenders. There are already investigations underway into Google, Apple, and Meta.45

Photo: A man talks on his mobile phone in front of the Houses of Parliament in London, Britain, August 17, 2021. Credit: REUTERS/Hannah McKay
Photo: A man talks on his mobile phone in front of the Houses of Parliament in London, Britain, August 17, 2021. Credit: REUTERS/Hannah McKay

United States

DMA Status: None

The Federal Trade Commission and the Department of Justice have both been active in litigating perceived anti-competitive practices by major digital platforms, with many of the actions started during President Donald Trump’s first term.46 On the digital competition front, changes to the premerger notification form were finalized in October 2024, signaling increased scrutiny of tech mergers and acquisitions.4748 It remains to be seen what approach the new administration will take with Big Tech. Could the new Trump White House take the European Commission to task over its treatment of US firms? Or will it seek to break up perceived monopolies on home turf?

Photo: Federal Trade Commission (FTC) Building. Credit: GSA Website https://www.gsa.gov/real-estate/gsa-properties/visiting-public-buildings/federal-trade-commission-federal-building
Photo: Federal Trade Commission (FTC) Building. Credit: GSA Website https://www.gsa.gov/real-estate/gsa-properties/visiting-public-buildings/federal-trade-commission-federal-building

Uzbekistan

DMA Status: Similar rules adopted

On August 3, 2024, Uzbekistan’s Resolution No. 256 went into effect.4950 The resolution specifically references large digital platforms though it is not a strictly ex ante regulation.51 Uzbekistan’s approach is notable for its extraterritorial provisions, applying obligations to digital platforms even beyond national borders. The impact of rulings from Uzbekistan remains an open question.

Acknowledgments

We extend our sincere gratitude to Rachel Wolbers and Kaitlyn Garman, Senior Fellow at CEPA's Tech Policy program, for their feedback and research contributions to this report. 

This webpage is up to date as of March 17, 2025. CEPA's Tech Policy Program will release an updated version of this map quarterly.

Ronan Murphy is Director of the Tech Policy Program at the Center for European Policy Analysis.

Bandwidth is CEPA’s online journal dedicated to advancing transatlantic cooperation on tech policy. All opinions expressed on Bandwidth are those of the author alone and may not represent those of the institutions they represent or the Center for European Policy Analysis. CEPA maintains a strict intellectual independence policy across all its projects and publications.

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