Digital Markets Act (DMA) Compliance: What Marketers Need to Know in 2025

In 2024 alone, EU DMA fines reached €4.48 billion, with tech giants and financial services firms getting hit hard. As marketing now depends more on digital platforms governed by the DMA, the risks of getting things wrong have multiplied.

The DMA services market is expected to reach around $2.91 billion in 2025 as companies scramble to adjust. Yet only 24% of marketers are currently fully compliant with the new standards, putting the other 76% in a risky position.

We made this guide to help marketing and compliance teams work better together. Because when non-compliance can lead to fines of up to 10% of your company's worldwide revenue, knowing these rules is necessary for your company to survive.

Introduction to the Digital Markets Act (DMA)

The Digital Markets Act is the EU's attempt to control the power of "Big Tech" companies and create more fair competition. Here's what makes it so important:

• Market Scope: Seven tech giants—Alphabet (Google), Amazon, Apple, ByteDance (TikTok), Meta (Facebook/Instagram/WhatsApp), Microsoft, and Booking.com—are now labeled "gatekeepers" controlling 24 core platform services. The European Commission designated the first six in 2023, and Booking.com joined the list in 2024, expanding the DMA into travel. These firms have billions of users and a combined value of trillions of dollars. Google holds over 90% of Europe's search market, and Apple/Google power almost all European smartphones.
• Economic Impact: Getting compliant costs a lot. Analysts estimate "tens of billions" in costs and possible fines. About 88% of companies spend over $1 million yearly on DMA compliance, with 40% spending over $10 million. This includes rebuilding systems and adding new user controls.
• Regulatory Reach: Though an EU law, the DMA affects companies worldwide. It applies to gatekeepers no matter where their headquarters are located, making U.S.-based tech giants follow the rules when operating in EU markets. Its effects are starting to influence digital rules globally.

This big change means marketers must rethink how they use these platforms that have become so important to their strategies.

What is the DMA and How Does it Impact Digital Marketing?

The DMA creates rules for large digital platforms before problems happen. Unlike traditional antitrust enforcement that acts after violations, the DMA sets clear boundaries about what gatekeepers can and cannot do.

Its main goals change how digital marketing works:

• More Competition: By opening up closed platforms, the DMA tries to give smaller companies a fair chance. For marketers, this means more options beyond the big players.
• More Fairness: The DMA stops practices like self-promotion or forced bundling that give gatekeepers an unfair edge. Marketers get more clear and steady access to platform services.
• One Set of Rules: The DMA creates one rulebook for all EU countries, making it simpler for campaigns that run in multiple European countries.

For digital marketing, the changes are happening now:

• More Ways to Reach Consumers: As people can switch defaults easier and try new services, marketers need to expand beyond the main platforms.
• Shifting Digital Power: The days of all-in-one platforms are ending. Google has already removed its Flights and Hotels boxes from EU search pages, sending traffic to other sites. This changes how travel marketers plan their digital approach.
• Better Data Access: Gatekeepers must give business users the data they create on platforms. For marketers, this means better visibility into how campaigns perform and audience information that was previously hidden.

These changes bring both difficulties and new possibilities for marketing teams used to working with a few dominant platforms.

Core Compliance Requirements for Marketing Activities

The DMA creates specific rules that change how marketing works on gatekeeper platforms. The key requirements affecting marketing strategies include:

• No Self-Promotion: Gatekeepers can't favor their own products in rankings. Google Search, for example, can't put Google Shopping results ahead of competitors, forcing marketers to rethink SEO and paid placement.
• Data Access: Advertisers must get tools to check ad performance on their own. Meta and Google now provide better analytics to let you audit impression data and conversion tracking, giving marketers more transparency.
• Fair Terms for Business Users: Platforms can't force unfair conditions or bundled services. For instance, app developers can now use payment systems other than Google Play's or Apple's App Store's, potentially lowering marketing costs and offering new ways to make money.
• More User Choice: Consumers can more easily change defaults, remove pre-installed apps, and switch between services. Marketers must prepare for more scattered attention as app store dominance no longer guarantees visibility.
• Third-Party Access: Gatekeepers must allow other apps and services to work with their platforms. This opens new marketing channels and integration options previously blocked by closed systems.

For marketing teams, these requirements call for new approaches:

• Media Planning: Budget allocations must consider emerging alternative platforms and new integration options.
• Data Strategy: With more data portability, marketers can build better cross-platform profiles while respecting user consent.
• New Partnerships: As middlemen gain more visibility (e.g., comparison shopping sites), marketers may need to build new relationships beyond direct gatekeeper channels.

The biggest marketing changes are happening in mobile app promotion, paid search, and social media advertising—areas most directly affected by gatekeeper restrictions.

DMA and Marketing Data: Privacy and Consent

The DMA works alongside the GDPR to improve user privacy while creating competitive opportunities. For marketers, this means being careful about how you handle data:

• Cross-Service Data Use: Gatekeepers can't combine personal data across services without clear user consent. Google and Meta have added new consent options for data sharing between their various platforms. Marketers must adjust to potentially smaller, separate audience segments when users say no to data combination.
• Consent Management: The DMA requires clear, simple interfaces for consent. Marketers should expect and prepare for more consent steps, which might reduce tracking abilities across gatekeeper platforms.
• Balancing Data Sharing with Privacy: While the DMA requires more data sharing and connectivity, GDPR still limits how personal data can be shared. Marketing plans must balance the new openness with ongoing privacy rules.

One big effect is on personalized advertising. Google's DMA compliance now asks EU users if they want their data connected across YouTube, Search, Maps, and other services. If users say no, marketers face more fragmented audience targeting and measurement problems.

Unlike earlier regulations, the DMA's privacy requirements directly support competition goals. This means marketers shouldn't see privacy compliance just as a legal requirement, but as part of a bigger shift toward a more varied, consent-based digital system.

Penalties and Enforcement: What Marketers Need to Know

The DMA's enforcement can have serious consequences for non-compliant gatekeepers and the marketers who use them:

• Big Fines: Violations can lead to penalties of up to 10% of a company's global annual turnover—going up to 20% for repeat offenders. For Apple or Alphabet, this could mean $20+ billion penalties. Marketers should expect that platforms will add strict compliance measures that could affect how campaigns run.
• Daily Penalties: Continued non-compliance can result in additional daily fines of up to 5% of average daily turnover. For major gatekeepers, this means millions per day, creating strong reasons to quickly fix violations even if it affects marketing features.
• Structural Changes: In cases of repeated non-compliance (three or more violations within eight years), the Commission can force structural changes—potentially including breaking up companies or making them sell off services. Such extreme measures would dramatically change the marketing platform landscape.

Already, the European Commission is looking into possible compliance failures by several gatekeepers. This active enforcement means marketers should:

1. Have Backup Plans: Be ready for sudden platform changes if gatekeepers must modify services to address violations.
2. Spread Platform Investments: Reduce dependency on any single gatekeeper to lessen business impact from compliance-related disruptions.
3. Stay Informed: Keep up with ongoing investigations and enforcement actions that could affect marketing channels.

The first enforcement actions expected in 2025-2026 will likely set the standard for future compliance requirements, bringing both clarity and potentially stricter interpretations of the rules.

Practical Steps for Marketing Compliance

For marketing teams working with gatekeeper platforms, getting ahead of DMA compliance requires specific actions:

1. Review Current Practices: Check all marketing activities on gatekeeper platforms to find dependencies on practices now prohibited under the DMA, such as exclusive arrangements or cross-platform data sharing without consent.
2. Fix Consent Processes: Make sure all user data collection and use across gatekeeper services follows DMA-compliant consent models, with clear opt-in options for data sharing between services.
3. Look at New Channels: As the DMA creates more competition, try emerging platforms and services that may offer new marketing opportunities outside the dominant gatekeepers.
4. Adjust Performance Measurement: With changes to data access and integration, update how you measure success and KPIs to account for potentially more fragmented user journeys across platforms.
5. Get Ready for Interface Changes: As gatekeepers add new choice screens and consent flows, adapt campaign designs and user paths to account for these additional steps in the customer journey.
6. Watch Campaign Results: Track how DMA-driven changes to gatekeeper services affect marketing performance metrics, and be ready to quickly adjust strategies as the regulatory situation changes.

Smart companies are already creating teams that combine marketing, legal, and technical expertise to handle this complex area.

Final Thoughts: Marketing in a DMA-Shaped World

The Digital Markets Act brings the biggest change to digital marketing since the GDPR. While compliance adds new complexities, it also creates opportunities for more transparent, diverse, and ultimately sustainable digital marketing approaches.

For marketers who have relied heavily on gatekeeper platforms, adjusting isn't optional. The combination of huge penalties, strong enforcement, and fundamental changes to how digital giants operate means business as usual won't work anymore.

The most effective marketing teams are treating DMA compliance not as a problem but as a push to develop more robust strategies that don't depend only on a few dominant platforms. By focusing on transparency, user choice, and fair competition, marketers can position themselves for success in this new regulatory reality.

At Luthor, we understand the problems marketers face in this quickly changing compliance environment. Our AI-based tool automatically checks marketing materials for compliance with regulations like the DMA and GDPR, helping you reduce risk, effort, and time dealing with marketing compliance at scale. Instead of manually checking each campaign element against complex regulatory requirements, Luthor gives automated assurance that your marketing meets the highest compliance standards.

Want to see how Luthor can help your team handle DMA compliance while keeping marketing effective? Request demo access today and find out how our technology can transform your compliance process from a bottleneck into a competitive advantage.

‍