Digital Markets Act (DMA): European Commission Specification Proceedings to Guide Google’s Compliance

As a landmark regulation reshaping digital competition in the European Union, the Digital Markets Act (DMA) continues to evolve in its practical application. On 27–29 January 2026, the European Commission formally initiated two specification proceedings aimed at supporting Google, one of the EU’s largest designated “gatekeepers”, in interpreting and implementing specific DMA obligations. This development is significant both for regulated undertakings and for any entity navigating digital compliance within the EU legal framework.

What Are the New Specification Proceedings?

The European Commission’s decision marks an important phase in the regulatory dialogue between EU authorities and Google. Rather than imposing sanctions upfront, the Commission has commenced formal specification proceedings designed to clarify how Google should comply with two fundamental DMA obligations:

1. Interoperability with Third-Party Developers:
   Under Article 6(7) of the DMA, gatekeepers must ensure that third-party developers receive free and effective interoperability with features of software or hardware that are critical to digital services. In Google’s case, this includes elements of its Android ecosystem that support accelerators for artificial intelligence (AI) services such as Gemini. The Commission will outline how Google must grant access to these features on equal terms with its own services, thereby enabling competitors to innovate and compete fairly.

2. Access to Anonymised Search Data:
   Pursuant to Article 6(11) of the DMA, Google must provide third-party providers of online search services with access to anonymised ranking, query, click, and view data on fair, reasonable, and non-discriminatory (FRAND) terms. The ongoing proceedings will define the scope of data, methodologies for anonymisation, access conditions, and even eligibility criteria for emergent AI providers such as large language model or chatbot developers.

These specification proceedings represent a practical implementation step rather than an enforcement sanction, reflecting the Commission’s use of collaborative regulatory dialogue to foster compliance.

Why Does This Matter? The Role of the Digital Markets Act

The Digital Markets Act, which entered into force on 1 November 2022 and applied broadly from May 2023, is one of the European Union’s most ambitious regulatory initiatives to ensure fair competition in digital markets. It targets large digital platforms — termed “gatekeepers” — that possess systemic control over core platform services such as online search, advertising, web browsers, app stores, and operating systems.

Unlike traditional competition enforcement, which typically reacts to anticompetitive conduct after the fact, the DMA sets forward-looking obligations designed to prevent conduct that could stifle fair competition or limit innovative entry into the digital marketplace. These include obligations relating to interoperability, data access, choice of default services, prohibition of self-preferencing, and transparency obligations between gatekeepers and downstream users or businesses.

The DMA’s implementation framework reflects a paradigm shift in EU regulatory policy, combining ex-ante rules with ongoing supervisory engagement. Proceedings such as those now initiated serve to operationalise statutory obligations, providing clarity where high-level legal norms require detailed interpretation. For regulated undertakings, this underscores the importance of early, robust, and documented compliance strategies.

What Companies Should Take Away

For legal and compliance professionals, as well as technology firms operating in the EU, the Commission’s actions carry several practical lessons:

• Compliance Is More Than Reporting: Gatekeepers must not only submit reports demonstrating how they meet DMA requirements, they must substantively operationalise those requirements through technical and organisational measures.

• Specification Proceedings Can Be Precedent: The current proceedings illustrate how regulators can issue structured guidance to tailor DMA obligations to specific technologies (e.g., AI-enabled services). This model could become more prevalent across future DMA enforcement actions.

• Implications for Non-Gatekeepers: Even companies that are not themselves designated gatekeepers should monitor DMA enforcement trends. Interoperability mandates and data access conditions may influence business models and data strategies if those enterprises rely on gatekeeper platforms for distribution, search, or advertising.

Συμπέρασμα

The European Commission’s launch of specification proceedings under the Digital Markets Act to clarify Google’s compliance obligations signals a more mature regulatory phase, moving from designation and reporting towards guided implementation and interpretive oversight. By formalising constructive dialogue and issuing clear interpretive frameworks, the Commission aims both to secure compliance and to support a more competitive and equitable digital market ecosystem within the EU.

As digital regulation continues to evolve, legal practitioners and corporate stakeholders must maintain proactive compliance frameworks that can adapt to regulatory guidance and emerging obligations in areas such as interoperability, data access, and platform openness.