The Digital Markets Act: Implementation Challenges and Interaction with Other EU Digital Legislation

With the EU Digital Markets Act (DMA) now in force, CIPL has transitioned from our initial research and assessment phase to active engagement on DMA implementation challenges. Building on our earlier work examining the intersection between the DMA and the GDPR, we are now focused on:

  • Identifying practical and legal challenges in implementing the DMA.

  • Exploring potential conflicts and overlaps with the broader EU Digital Strategy and related regulatory frameworks.

  • Analyzing early findings on the DMA’s impact on businesses, data governance, and digital innovation.

As part of this evolving project, CIPL continues to serve as a trusted forum for multi-stakeholder dialogue, bringing together:

  • Industry leaders and digital platforms

  • EU policymakers and the European Commission

  • Data Protection Authorities (DPAs) and regulatory bodies

  • Academic and legal experts

Through a series of roundtables, expert workshops, discussion papers, and strategic engagements, CIPL aims to support effective, coherent, and innovation-friendly implementation of the Digital Markets Act across the European digital economy.

Key milestones in our engagement with the Digital Markets Act:

2021

Our white paper titled Bridging the DMA and the GDPR, analyzed how the DMA’s obligations involving personal data interact with the General Data Protection Regulation (GDPR). The paper also examined the operational consequences of the DMA obligations for gatekeepers and organizations receiving or accessing personal data.

2023

We published Limiting Legal Basis for Data Processing Under the DMA, examining potential limitations imposed by the DMA on legal bases for personal data processing and its relationship with the GDPR.

2024

We published Data Sharing Obligations Under the DMA: Challenges and Opportunities, a paper exploring the implications of the DMA on the digital ecosystem. This third paper in the series analyzed the operational consequences of the DMA obligations for gatekeepers and organizations receiving or accessing personal data, specifically in the context of Article 6(9) of the DMA.

Our op-ed in Euractiv titled When the Dust Settles: Remaining Questions of Privacy vs Utility under the DMA, discussed ongoing challenges and considerations in balancing privacy and utility in the context of the DMA’s implementation.

2025

Our op-ed Digital Markets Act in Practice – Are We Headed in the Right Direction? Where Contestability Meets Security explored the trade-offs between contestability and security, highlighting concerns about the DMA obligations in the context of security.

Our DMA Project offers CIPL members and project participants unique opportunities for engagement, development and strategy building including:

Regulatory Compliance and Strategy

  • Expert guidance on meeting the Digital Markets Act (DMA) requirements for gatekeepers and digital platforms.

  • Supporting project participants through with regulatory engagement, policy interpretation, and documentation.

Policy Innovation and Stakeholder Engagement

  • Driving dialogue between regulators, industry leaders, and civil society to shape responsible DMA implementation.

  • Hosting high-impact roundtables, workshops, and policy forums to foster multi-stakeholder collaboration.

  • Generating insights and white papers on future-focused digital policy trends.

Thought Leadership and Capacity Building

  • Publishing cutting-edge research and analysis on the DMA’s implications across the digital ecosystem.

  • Empowering member organizations through training, webinars, and toolkits focused on DMA readiness.

  • Positioning CIPL as a global voice in digital governance and data responsibility.

  • Collaborating with academic and international bodies to drive best practices in digital market regulation.