154 submissions from 130 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 3,038 submissions on this file. Shown here: the 154 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
Who showed up
102 submissions from industry — companies and their trade associations — against 35 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 2.9 industry submissions for every one from civil society.
Industry 102Civil society 35Public authorities, academia, other 17
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
76 of 130
in the EU Register
359
full-time lobbying staff
€64.5M+
declared costs a year
283
EP accreditations declared
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 5 May 2021 — it ran from 16 Dec 2020.
Digital Markets Act – Comments to EC Proposal Introduction Mediaset welcomes the proposed Regulation on the Digital Markets Act (DMA) as an important step to re-establish fair competition in digital markets. In fact, due to a mix of first mover advantage, exclusionary and anti-competitive practices, a few systemic gatekeeping platforms have reached an unmatchable market power throughout the internet economy.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The European Games Developer Federation e.f. (EGDF) unites national trade associations representing game developer studios based in 19 European countries: Austria (PGDA), Belgium (FLEGA), Czechia (GDACZ), Denmark (Producentforeningen), Finland (Suomen pelinkehittäjät), France (SNJV), Germany (GAME), Italy (IIDEA), Malta (MVGSA), Netherlands (DGA), Norway (Produsentforeningen), Poland (PGA), Romania (RGDA), Serbia…
PostEurop is the trade association representing Universal Service Providers (USPs) for post. As USPs, PostEurop’s members ensure everyone is connected and has access to postal services, enabling consumers and SMEs to send and receive letters and parcels wherever they are. This contributes to economic growth and social cohesion across the EU.
AFNUM would like to welcome the proposal for a Regulation on Digital Market Act (DMA) presented by the European Commission on 15 December 2020. This text marks an important development by proposing to create the necessary conditions and regulatory framework for a stronger and more competitive digital single market in the EU.
Filed in French · English published by the European Commission
Brussels, 5 May 2021 OPENFORUM EUROPE’S FEEDBACK ON THE COMMISSION’S PROPOSAL FOR A DIGITAL MARKETS ACT OpenForum Europe is a not-for-profit, independent European based think tank which focuses on openness within the ICT sector. User centricity based on the principle of competition is central to our vision and mission. In line with this, we welcome the European Commission’s proposal for a Digital Markets Act (DMA).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
5 May 2021 FEEDBACK ON THE EUROPEAN COMMISSION'S PROPOSAL FOR THE DIGITAL MARKETS ACT 1. BACKGROUND ON ECIS 1. The European Committee for Interoperable Systems ("ECIS") is an international, non-profit association of information technology companies founded in 1989 which endeavours to promote a favourable environment for interoperable ICT solutions.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
ZAW expressly welcomes the fact that an initiative is being taken at European level to adapt antitrust law to the changed market conditions in the digital world. The DMA is at the heart of existential regulatory issues for the digital advertising industry given the overwhelming market power of the dominant intermediaries (gatekeepers). The DMA is an important step in the right direction.
The Digital Markets Act – Suggestions to increase the effectiveness of the European Commission's Proposal 1. Oracle provides products and services that address enterprise information technology (IT) environments.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Achieving a functioning and economically and culturally balanced internal market requires the creation of a level playing field and a level playing field in digital markets and in the online world. The private broadcasting organisations in Germany, with a turnover of around EUR 11,4 billion in 2019, are a major cultural and economic factor.
Filed in German · English published by the European Commission
Women in AI Austria welcomes the opportunity to comment on the proposed Digital Markets Act. We commend the work of the European Commission in developing such a comprehensive framework for digital markets and believe it will be indispensable for the development of these services and markets in a way that respects, upholds and elevates European users and businesses.
5Rights Foundation welcomes the Commission proposal for a Digital Services Act (DSA), and its ambition to create a safer digital space in which the fundamental rights of all users of digital services are protected. In order to fulfil this ambition, the DSA needs to go further to ensure the respect of children's rights by all digital service providers. Children make up one in five users of digital services in the EU.
Audiovisual production is a prototype industry in which risk-taking is important. No income or success is guaranteed. Thus, it is absolutely essential for professionals in the sector not only to return to the success of each work, but also to combat all forms of illegal consumption, devaluating its prestige and causing a significant loss of turnover when the risks taken were significant. ......
Filed in French · English published by the European Commission
1.- Our association is made up of associations and rights management organisations from various cultural content sectors — film, book, music, video games — whose main purpose is to protect intellectual property rights in the digital field; In particular, the fight against illegal activities carried out through digital services, as well as the promotion of the legal offer of content.
Filed in Spanish · English published by the European Commission
European Commission Consultation - Proposal for a new Digital Markets Act - Airbnb Response 1. Airbnb Ireland UC (“Airbnb”) welcomes the opportunity to respond to the European Commission’s consultation on its proposal for new regulation on contestable and fair markets in the digital sector (“Digital Markets Act” or “DMA”).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Please find Bitkom's five principles for the functioning of the digital economy and fair competition attached: 1.) Retain core competition mechanics: Scope should be based on objective evidence. 2.) Taking diversity into account: Obligations should not follow a one size fits all approach. 3.) Reliable rules: Application and rules must be clear and targeted.
DIGITAL SME strongly welcomes the Digital Markets Act proposal. We think that it has strong elements to create a level-playing-field in digital markets which fosters innovation, and to provide opportunities to new market entrants. At the same time, we would like to raise a few additional points, which are outlined in the following pages, including: - According to Art.
ACT member companies finance, produce, promote and distribute content and services benefiting millions of Europeans across all platforms. At ACT we believe that the healthy and sustainable commercial broadcasting sector has an important role to play in Europe’s economy, society and cultures.
CANAL+ Group is a major European audiovisual player investing heavily in premium content and having the ambition to export European culture on the continent and beyond. Like all European players, the Group is facing an extremely unbalanced competition from very large online platforms playing a role of gatekeeper and having recourse to various unfair commercial practices.
The Electronic Frontier Foundation is among the leading non-profit organizations defending civil liberties in the digital world. We welcome the option to give feedback on the proposed Digital Markets Act (DMA). Our detailed positions on the Digital Services Act and the Digital Markets Act can be accessed at https://www.eff.org/issues/eu-policy-principles.
News Media Europe position paper on the European Commission proposal for a Digital Markets Act (DMA) April 2021 News Media Europe (NME) represents the progressive news media industry in Europe – over 2,500 media companies including newspapers, radio, television and internet.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Regarding the data access provisions of the DMA, we have two comments: 1. The provision for giving business users access to data generated through their activities and of respective end users can have transformational impact on the relative power of dominant platforms and their business users. Such access is rightly both for aggregate and non aggregate data, and personal (with safeguards) and non personal data.
ProSiebenSat.1 welcomes the European Commission’s efforts to bring about far-reaching and sustainable regulation by adapting European competition law in order to ensure fair competition in the EU’s Digital Single Market and to prevent anti-competitive structures and business practices.
Filed in German · English published by the European Commission
The Counter Extremism Project (CEP) is an international, nonprofit policy organisation engaged in efforts to regulate social media and video sharing companies since 2015. Our focus lies on extremist ideologies and illegal and terrorist content online. CEP advisors have been working with EU institutions and EU Member States for the past several years on some of the key issues the DSA aims to regulate.
Contributo sulla proposta di regolamento Digital Markets Act La proposta di regolamento COM (2020) 842 final, cosiddetto Digital Markets Act (DMA) propone una serie di attesi interventi volti a contrastare le pratiche commerciali sleali messe in atto da alcune grandi piattaforme online e i problemi derivanti dal considerevole grado di dipendenza degli utenti commerciali e dei consumatori da tali piattaforme.
Filed in Italian · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The World Federation of Advertisers (WFA) is the voice of marketers worldwide, representing 90% of global marketing communications spend – over €800 billion per year – through a unique, global network of the world’s biggest markets and biggest marketers. WFA champions responsible and effective marketing communications worldwide. We represent 128 brand owners and 60 national advertiser associations across the world.
VDZ Verband Deutscher Zeitschriftenverleger e.V. BDZV Bundesverband Digitalpublisher und Zeitungsverleger e.V. Rückmeldungen zum Entwurf der EU-Kommission für einen Digital Markets Act v. 15.12.2020 (COM(2020) 842) – im Folgenden DMA-E (Stand: 5. Mai 2021) A.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The EU proposal for a Digital Markets Act Executive summary We welcome the opportunity to comment on the recently published proposal for a Regulation on a Digital Markets Act (DMA). These new rules respond to the need to address recurring problems and structural challenges present in digital markets, complementing competition policy.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
As the EU considers how best to design the DMA, it is vital that any such new tool is clear in terms of its scope, including the companies to which it may apply; the obligations they may be subject to; and the DMA’s interaction with existing legislation at both EU and Member State level. It is also important that the DMA contains appropriate procedural safeguards.
04 May 2021 Digital Services Act package – Ex ante regulatory instrument of very large online platforms acting as gatekeepers Lie Detectors response to public consultations Lie Detectors, an award-winning journalist-led media literacy campaign in Europe, welcomes the ability to respond to the Commission consultation on the Digital Services Act package.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The European Broadcasting Union (EBU) , representing public service media organisations in Europe, supports the proposed Digital Markets Act’s objective to create a fairer and more contestable digital space by establishing a strong rulebook for online gatekeeper platforms. Such rules are key to support fundamental values such as cultural diversity and media pluralism.
ESBG and its Members fully support efforts to ensure that European digital markets remain fair and open to all innovative service providers. 1. The DMA establishes a set of narrowly defined objective criteria for qualifying a large online platform as a gatekeeper.
We firmly support the DMA. Digital platforms have grown rapidly over the past decade. Time is of the essence to assess their ability to set the rules of the market, and to set fair conditions across the economy. We welcome the proposal, not just because we share the objectives it pursues, but also because we believe it follows a practical approach that can make it successful.
Adigital shares the objective of the markets remaining fair and contestable for innovators, business and market entrants, and understands the final goals of the Digital Markets Act. However, we consider that some elements should be clarified to avoid the possibility of having unintended effects and harmful consequences in the ecosystem both on consumers and business users of platforms.
Leaseurope feedback to the Digital Markets Act Leaseurope, the European Federation representing the leasing and automotive rental industries, fully supports the European Commission’s aim to improve transparency and oversight of online platforms through the Digital Markets Act.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
5 May 2021 AEB position on the Proposal for a Regulation on a Digital Markets Act Introduction The Spanish Banking Association (AEB) welcomes the opportunity to comment on the proposal for the Regulation on the Digital Markets Act (DMA). Digital platforms have grown rapidly in the last decade.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
EU Commission consultation Digital Services Act package – ex ante regulatory instrument of very large online platforms acting as gatekeepers May 5, 2021 Das NETTZ - Vernetzungsstelle gegen Hate Speech (networking initiative against hate speech, betterplace lab): www.das-nettz.de, [email removed] We call on the EU Commission to make digital spaces a safe place for all people.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Heureka Group, a.s. (an operator of comparison shopping service) very much welcomes the European Commission's initiative in the form of the draft DMA and considers it a step in the right direction. However, in the current draft DMA it is possible to identify several unclear or imprecise points which, in the opinion of Heureka Group, should be addressed further in the legislative procedure by respective stakeholders.
Free Knowledge Advocacy Group welcomes the initiative to supplement the Digital Services Act with the proposal for a Regulation on contestable and fair markets in the digital sector (Digital Markets Act). The online ecosystem has been lacking an adequate framework, in which there is a differentiation between platforms considered to be the gatekeepers and other models of online intermediation.
Dear Madam, dear Sir, On behalf of SMEunited, I would like to inform you that we are not able to provide feedback on this consultation within the deadline of today (5 May). Due to the huge number of consultations, we are still discussing our position paper with our member organisations and we would be glad if you could accept our feedback that will be finalised in the upcoming days.
IBM welcomes the Commission’s Digital Markets Act (DMA) proposal and the opportunity to provide feedback. IBM agrees that action is needed to ensure fairness and contestability of certain digital markets, especially those that are data-driven. We believe that the Digital Markets Act contains the right mechanisms to restore both fairness and contestability in those digital markets.
Please find attached the recommendations of the Descartes Foundation concerning the DSA. An independent, independent, civic and European initiative, the Descartes Foundation is a multi-disciplinary research institute based in Paris and founded in 2019, dedicated to information and public debate issues at internet and social media time.
Filed in French · English published by the European Commission
1. Introduction The European Gaming and Betting Association (EGBA) is the Brussels-based industry body, that represents leading online gaming and betting operators established, licensed and regulated in the EU. This position paper elaborates on our main concerns regarding the European Commission’s (EC) proposal for a Digital Services Act (DSA), which can impact the legitimate provision of online gambling services to…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
We agree with the general objectives of the Commission’s proposal for the Digital Markets Act. The proposed regulation will bring clear benefits for the SME users of the gatekeeper platforms who currently lack effective means to address their unfair practices.
The Computer & Communications Industry Association (CCIA) welcomes this opportunity to provide feedback on the European Commission’s proposal for a Digital Markets Act (DMA). CCIA represents large, medium, and small companies in the high technology products and services sectors, including computer hardware and software, electronic commerce, telecommunications, and Internet products and services.
POSITION STATEMENT Proposal for a Regulation on contestable and fair markets in the digital sector In summary ➢ FSB welcomes the intention to complete the digital single market and establish a horizontal regulatory framework that will establish a level playing field for small business users of online platforms.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
FIGIEFA is the European Federation which represents the businesses of independent wholesalers and retailers of automotive replacement parts and their associated repair chains, together with its 20 National (European) members.
(1) Dark patterns and manipulation of consumers: Risk of circumvention of DMA obligations: The proposal does not refer to the gatekeepers’ use of so-called “dark patterns”. Dark patterns surreptitiously influence consumers’ behaviour by manipulative interface de-signs that exploit consumers’ behavioural biases .
The European Commission has tabled an ambitious proposal for keeping digital markets fair and open. Booking.com supports this ambition. A few digital platforms have become so powerful that they are unavoidable trading partners. Often they control entire digital ecosystems. Businesses are dependent on them for access to consumers.
Together with the Digital Markets Act (DMA), the European Commission aims to strengthen the EU’s single market for digital services. SYNTEC Numérique and TECH IN France welcomed this approach and supported a stronger and more competitive Digital Single Market for the benefit of both European businesses and consumers.
Filed in French · English published by the European Commission
Liberty Global welcomes the opportunity to provide feedback on the European Commission’s proposal for a Digital Markets Act (DMA). Liberty Global also provided feedback to the proposal for a Digital Services Act. Our position on some key items is below - our response is attached.
Please find attached the feedback of ACT | The App Association (Transparency Reg. # 72029513877-54) to the European Commission’s adopted "Digital Markets Act" proposal. Anna Bosch Policy Associate ACT | The App Association (Transparency Reg. # 72029513877-54) Rue de Trèves 45 B-1040 Brussels
We strongly call on the European co-legislators to ensure accessibility of digital platforms and services, so that European law best serves the interest of all Union citizens, including of more than 100 million EU citizens with disabilities. The explanatory memorandums for the Proposals make references to the UN Sustainable Development Goals and mention social sustainability.
Open-Xchange would like to thank for the opportunity to provide comments on the Commission’s proposal for the new Digital Markets Act. We generally support the Commission’s objectives and stand in favour of enacting a new regulation building on the draft. We nonetheless raise some issues building on our first-hand experience in one of our core fields of activity, Internet email and messaging in general.
Our mission is to provide a collective voice for software developers and to represent their interests on matters affecting the software development ecosystem. From this perspective, we see the potential benefits of the DMA, but also predictable spillover effects on certain digital ecosystems, raising the cost of doing business for developers, as well as a negative impact on investment in the EU digital markets.
eco – Association of the Internet Industry has followed the discussion for the development of complementary competition provisions that differ from existing competition law principles, and generally welcomes a European approach. With the proposal on the DMA, the EU Commission wants to launch provisions that allow direct application and enforcement for certain issues by the EU Commission.
Our organisation welcomes the DMA proposal. In our opinion, the ex-ante approach to regulating gatekeepers suggested in the proposal has the potential to reduce harmful impact of their conduct on digital markets. We have outlined few minor suggestions regarding the text of the proposal in the attached document.
Stellungnahme Nr. 35 April 2021 Registernummer: 25412265365-88 Digital Markets Act – Opinion of BRAK Mitglieder des Ausschusses Kartellrecht RAin Dr. Ellen Braun, LL.M. (Berichterstatterin) RA Dr. Matthias Karl, LL.M. RA Dr. Moritz Wilhelm Lorenz (Berichterstatter) RA Dr. Andreas Lotze RA Dr. Martin Schwarz RAin Dr. Dominique Wagener RA Dr.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Summary - MEDEF welcomes the Digital Markets Act (DMA), marking a major step in the project to regulate the most structuring digital platforms to ensure more effective operation of the internal market. This is an issue of sovereignty and fair competition for French and European companies.
EMMA and ENPA Position paper on the Proposal for a regulation on contestable and fair markets in the digital sector Digital Markets Act 23 March 2021 The European Newspaper Publishers Association (ENPA) and the European Magazine Media Association (EMMA) together represent the majority of European press publishers with a variety of press offerings in magazine and newspaper form, both digital and print.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
When discussing on Europe`s digital future with the Digital Services Act, we ask the European Commission and its’ representatives to address the responsibility of networks towards the promotion of animal welfare. Next to relevant topics such as hate speech and disinformation, all kind of content portraying animal suffering which is not shared for informal reasons need to be regulated on all social networks.
At Microsoft, we support the development of the new rules under the Digital Markets Act (DMA) to address gatekeepers and tackle structural competition problems in digital markets. We share the European Commission’s objective of creating a level playing field for businesses to invest, innovate, and grow and ensure that technology works for the benefit of societies, citizens, and consumers.
Allied for Startups welcomes the opportunity to give feedback on: “Digital Services Act – ex ante regulatory instrument of very large online platforms acting as gatekeepers”. Startups are the ultimate competitors of our economies. They are born out of the very essence of competitive thought - they aim to challenge any established players in any given markets - digital or analog.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
EMISA welcomes and supports the objective of the DMA for fair and contestable digital markets. Most important is that the scope of the proposal becomes as broad as this objective and focuses on gatekeepers that can foreclose and distort competition from their direct competitors on the platform.
Avril 2021 Position du Groupe La Poste Proposition de règlement relatif aux marchés contestables et équitables dans le secteur du numérique ou « Digital Markets Act » Le Groupe La Poste se réjouit de pouvoir partager ses positions à l’occasion de la consultation publique de la Commission européenne sur la législation sur les marchés numériques ou « Digital Markets Act ».
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Following the adoption of the European Commission’s proposals for regulations on the Digital Services Act (DSA) and the Digital Markets Act (DMA) on 15 December 2020, COMECE Secretariat would like to submit its feedback to the European Commission in the attached file.
Access Now welcomes the opportunity to provide comments on the European Commission’s proposal for a Digital Markets Act (DMA). We share the Commission’s assessment that gatekeeper platforms’ behaviour leads to “inefficient market outcomes in terms of higher prices, lower quality, as well as less choice and innovation to the detriment of European consumers.” We support the goal set by the Commission to address…
TELEFONICA’S POSITION ON THE COMMISSION’S DIGITAL MARKETS ACT (DMA) PROPOSAL EXECUTIVE SUMMARY Telefónica endorses the objective to promote fair and contestable markets by regulating the activities of platform service providers with significant impact on the Internal Market. We believe that there are a number of ways the effectiveness of the proposal could be improved.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
MVNO Europe welcomes the Commission’s intention to deal with unfair practices and lack of contestability that it has identified for a number of core platform services – including operating systems – and that have led to inefficient outcomes in the digital sector in terms of higher prices, lower quality, as well as less choice and innovation to the detriment of European consumers.
The European Regulators Group for Audiovisual Media Services (ERGA) would like to express its endorsement for the general principles underpinning the proposal on the DMA, such as ensuring that digital markets remain fair and open to all innovative service providers, small or big.
Media organisations generally welcome the European Commission’s legislative proposals for a Digital Services Act and a Digital Markets Act. They represent an important step towards strengthening the European single market and refocus on the much needed prerogatives of the legislator in the context of regulating global online services.
Filed in German · English published by the European Commission
BEUC strongly welcomes the proposed Digital Markets Act. It is a good starting point to adopt an essential new law to tackle problems in digital markets. In particular, BEUC welcomes the fact that this proposal is a Regulation with a swift entry into application; contains self-executing obligations and prohibitions; and will be enforced at EU level.
BELTUG, CIGREF, CIO PLATFORM NEDERLAND and VOICE represent business users of digital technologies in Belgium, France, the Netherlands and Germany. We form communities of Chief Information Officers (CIOs) and other senior leaders who are responsible for digital technologies and digital transformation within private or public organisations.
FEDMA thanks the European Commission for the opportunity to submit feedback to the “Proposal for a Regulation on contestable and fair markets in the digital sector (Digital Markets Act - DMA). We invite everyone to read our full submission in the attachment.
SGI Europe welcomes overall the Digital Markets Act (DMA) of the European Commission and the opportunity to reflect again on the proposal for a regulation in the public feedback consultation. The DMA is an important starting point to ensure fair competition in the digital world and increase consumer choice.
We welcome the Commission’s unprecedented ambition in opening up digital markets with the Digital Markets Act (DMA). We concur that it is critical to dilute the power of online gatekeepers, for the good of society, innovation, and competition.
Amnesty International welcomes the DMA’s focus on levelling the playing field and addressing the dominant role of gatekeepers over the online environment. However, Amnesty believes the DMA should put more focus on end-users and be more ambitious to allow competitors to the gatekeepers to emerge that offer more choice and better conditions to end-users. 1.
Seznam.cz is an online platform and media company based in Czech Republic, with dozen of services like news, entertainment, general search engine, freemail, maps, price comparison tools and others. With more than 1500 employees, 90% reach in Czech population and yearly revenue above 150 mil. EUR, Seznam.cz represents a significant and valuable European online company.
The European Publishers Council (“EPC”), a high-level group of Chairmen and CEOs of Europe’s leading media and publishing groups representing companies with newspapers, magazines, online publishing, journals, databases, books, eLearning, online marketplaces and radio and TV broadcasting, warmly welcomes the Commission’s Proposal (the “Proposal”) for a Digital Markets Act (“DMA”), which represents a significant step…
Privacy International (PI) welcomes the aim of the Digital Markets Act (DMA) to address some of the challenges posed by the way the current digital markets operate. However, we believe that the proposal put forward by the European Commission in December 2020 contains some shortcomings that need to be addressed, if the DMA were to be effective in tackling these challenges.
As an association of major French companies and public administrations, Cigref's mission is to develop the capacity of its member organisations to integrate and master digital technologies. Cigref welcomes the Commission's ambitions to ensure effective competition in the digital services market. Digital service providers are the essential backbone of many business users.
5 March 2021 ITI Comments to The Digital Markets Act Proposal As the global voice of the tech industry, ITI - The Information Technology Industry Council - welcomes the possibility to provide comments on the recently published Digital Markets Act proposal.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Wien, am 13. Januar 2021 Stellungnahme zum Vorschlag der Europäischen Kommission eines Digital Markets Acts („DMA“) Einleitung und Vorbemerkung Der DMA zielt auf die spezifischen Herausforderungen ab, die durch das Entstehen großer mehrseitiger Online-Plattformdienste entstanden sind.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Eu travel tech strongly supports the proposal of the European Commission for a Digital Markets Act. Digital platforms bring important benefits for European consumers and contribute to the internal market by increasing consumer choice, opening new business opportunities and facilitating cross-border trading.
EACA, the European Association of Communications Agencies, and its members welcome the Commission’s intentions to make sure that businesses operating and competing in the digital sector can do so freely and fairly. We are pleased to note that one of the major concerns we raised in relation to the platform-to-business regulation has eventually been integrated into the present proposal.
Prepared for the European Commission Feedback on the New Competition Tool and ex-ante regulation of digital undertakings with gatekeeping power1 30 June 2020 Introduction 1. While we acknowledge that the digital transformation generates vast social benefits, we also recognize the widespread concerns about the potential monopolization of digital markets by a handful of powerful global platforms.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Comments on: New Digital Services Act package: Ex ante regulatory instrument for large online platforms with significant network effects acting as gate-keepers in the European Union’s internal market – Inception Impact Assessment [name removed], Professor of Competition Law, TILEC, Tilburg University1 Contact details: [email removed] Thank you for the opportunity to comment on this initiative.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
At Apple, our mission is to make hardware, software and services that help people make the world a better place. We design our products and services to create a streamlined and effortless user experience that sets the industry standard for privacy protection and digital security.
The Wikimedia Foundation and the Free Knowledge Advocacy Group EU welcome the initiative of devising ex ante rules to ensure that markets characterised by large online platforms remain fair and contestable for innovators, businesses, and new market entrants.
Deliveroo is an online restaurant food delivery company, founded in 2013 in London and today operates in 12 markets, including 6 EU countries. The EC’s proposal to implement a digital services act ex ante regulation is not appropriate for the online restaurant food delivery sector and will decrease competition.
Oxera is pleased to provide feedback on the Commission’s initiative for an Ex Ante regulatory framework for online platforms. In the interests of transparency, we would like to state that we are currently advising several technology firms and an industry body on issues around the Digital Services Act. The feedback and opinions provided here are entirely our own.
June 30, 2020 Facebook observations to the Inception Impact Assessment on the DSA Ex- Ante Instrument of very large Online Platforms acting as Gatekeepers 1. Introduction Facebook welcomes the opportunity to provide its insights and observations in response to the European Commission’s Ex-ante “Gatekeeper” inception impact assessment (IIA).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
ARTICLE 19 welcomes the opportunity to provide feedback to the inception impact assessment on ex ante regulatory instrument of very large online platforms acting as gatekeepers. The attached document contains a joint statement on behalf of a number of civil society organisations.
The Electronic Frontier Foundation (EFF) is among the leading non-profit organizations defending civil liberties in the digital world. We welcome the opportunity to provide feedback to the European Commission and to highlight what matters most: the E-Commerce Directive should be apt to deal with the challenges brought by a digital space that is monopolized by a few platforms and where alternative platform models and…
The European Banking Federation (EBF) welcomes the European Commission’s initiative to address the issues with regard to large online platforms with significant network effects acting as gatekeepers and welcomes the opportunity to respond to the published Inception Impact Assessment (IIA) on a possible ex-ante regulatory instrument.
Athens, 30.06.2020 Feedback regarding the ex-ante regulatory instrument of very large online platforms acting as gatekeepers Homo Digitalis is a Greek civil society organisation based in Athens that focuses on the promotion and protection of human rights in the digital age. We are also members of the European Digital Rights (EDRi) network.
Shopify was founded in 2006 by German-born Tobias Lütke with the goal of helping to democratize commerce. Fourteen years later, our ecommerce platform is used by over 1 million entrepreneurs and small businesses globally. Today, over 100,000 European businesses, many of them small and medium-sized enterprises, have used Shopify to generate USD 319 Billion of economic activity, creating over 2 million full-time jobs.
Preliminary views on the European Commission’s Impact Assessments regarding the Digital Services Act and New Competition Tool 1. INTRODUCTION 1. On June 2, 2020, the European Commission (“Commission”) launched public consultations regarding a proposed Digital Services Act (“DSA”) and a proposed New Competition Tool (“NCT”).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Digital Services Act package: Ex ante regulatory instrument for large online platforms with significant network effects acting as gate-keepers in the European Union’s internal market Inception Impact Assessment Comments by Mediaset S.p.A. In the early 2000s the internet was idealised as an open space in which citizens could gather information, share their opinions and develop ideas.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Vodafone welcomes the publication of the European Commission roadmap/Inception Impact Assessment: Ex ante regulatory instrument for large online platforms with significant network effects acting as gate-keepers in the European Union’s internal market.
Polish Business Society appreciates the Commission's efforts to address regulatory issues which appeared in recent years on the digital market and to contribute to this important debate. This initiative offers as very important and needed to solve the market distortions. Digital market is characterized by significant dynamics.
Free Knowledge Advocacy Group, welcomes the initiative of devising ex ante rules to ensure that markets characterised by large online platforms remain fair and contestable for innovators, businesses, and new market entrants.
Microsoft appreciates the opportunity to comment on the European Commission’s Inception Impact Assessment regarding the development of an appropriate regulatory framework to address certain practices of online platforms acting as “Gatekeepers.” We support the Commission’s objective to ensure that markets impacted by Gatekeepers remain fair and contestable and to improve regulatory oversight over such platforms.
Response of the MEDEF to the consultation of the European Commission — see attached document As part of the launch of two impact studies, the European Commission is planning to: The introduction of a “New competition tool”, and/or An ex ante regulatory instrument for large online platforms with significant network effects which may play a role in access to certain markets within the European Union (‘large platforms…
Filed in French · English published by the European Commission
The attached document contains a joint statement on behalf of a number of civil society organisations in response to the inception impact assessments on a new competition tool and an ex ante regulatory instrument of very large online platforms acting as gatekeepers.
Bol.com welcomes the opportunity to respond to the Digital Services Act (DSA) Inception Impact Assessment (IIA) on 'ex ante regulatory instrument for large online platforms with significant network effects acting as gate-keepers in the European Union’s internal market'.
Consultation on the European Commission’s Inception Impact Assessment Concerning the possible Ex Ante Regulation of Platforms and the New Competition Tool Google’s Submission June 30, 2020 Table of contents Introduction 2 General Principles 3 Aspects regarding an E x Ante Regulatory Instrument 5 Aspects regarding a ‘New Competition Tool’ 9 Conclusion 11 1.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
This submission outlines Booking.com’s thinking on the proposed New Competition Tool and ex ante regulation for large online platforms with significant network effects acting as gatekeepers. We are submitting it in parallel to both consultations. We at Booking.com believe in the benefits of competition. It is at the core of our business model.
The European Publishers Council (EPC) welcomes the opportunity to comment on the Road Map for the Digital Services Act package: ex ante regulatory instrument of very large online platforms acting as gatekeepers. Please find attached our short contribution.
Allied for Startups welcomes the opportunity to provide feedback to the Inception Impact Assessment concerning the ex ante regulatory instrument of the Digital Services Act package. Please find attached our feedback and do not hesitate to reach out if you have questions. Allied for Startups is a worldwide network of over 40 advocacy organisations focused on improving the policy environment for startups.
Having established a new category between telecommunication infrastructures and media publishers, EU legislators should establish that platforms have publisher-like liability for the content they spread. In implementation terms, this would also differentiate between illegal content (justifying an obligatory notice-and-take-down regime for user-generated content) and disinformation (which is intentionally harmful and…
There is an urgent need to create fair competitive conditions in the platform industry. RECOGNISE THE WORKER DIMENSION Throughout the Digital Services Act (DSA) documents there is mention of consumers, sellers and intermediaries, but no mention of platform workers, while workers are just as much a part of this equation.
DSA Package: Response by the Netherlands on Inception Impact Assessment of an ex-ante regulatory instrument for large online platforms acting as gatekeepers in the internal market. The Netherlands shares the idea expressed in the inception impact assessment that whereas platforms bring enormous benefits, a small amount of large platforms may be in a position that has allowed them to act as gatekeepers, with adverse…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
DSA ex ante regulation and New Competition Tool – Amadeus position on Commission’s Inception Impact Assessment 1. Relevance to Amadeus Amadeus is one of Europe’s leading technology companies and a technology provider to the global travel and tourism industry, serving customers in more than 190 countries.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
On behalf of the undersigned civil society organisations on this submission, Rights International Spain is pleased to submit feedback to the European Commission’s roadmap titled “Digital Services Act package. Kind regards, [name removed] (Rights International Spain)
On behalf of the undersigned civil society organisations on this statement, Access Now calls on the European Commission to consider human rights issues in its competition policies and potential regulatory actions. We believe that this small number of large online platforms not only act as economic gatekeepers, but also as 'fundamental rights' gatekeepers.
Brussels, 30 June 2020 Joint statement in response to the inception impact assessments on a new competition tool ex ante regulatory instrument for large online platforms acting as gatekeepers We are pleased to see that the European Commission is reviewing its regulatory toolbox in response to the challenges posed by large online platforms in numerous digital markets, and we welcome the possibility to provide…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
On behalf of the Center for Data Innovation, we are pleased to submit feedback to the European Commission’s roadmap titled “Digital Services Act package: Ex-ante regulatory instrument of very large online platforms acting as gatekeepers” (please see attached).
EuroCommerce welcomes this opportunity to provide input to the roadmap consultations on an ex ante platform instrument. The area is of high importance to the future and competitiveness of the retail and wholesale sector in an increasingly digital environment.
European Tech Alliance position on Digital Services Act Impact Assessment: ex ante regulatory instrument of very large online platforms acting as gatekeepers We are grateful for the opportunity to comment on the European Commission’s Inception Impact Assessments on DSA initiatives.
The content of the Digital Service Act Package is a matter of shaping the legal framework for the next decades in an essential and very dynamic business sector. It is a very important project and there is also a need for a swift process. Therefore, it is very important to involve the responsible government representatives in advance so that the legislative project can then be implemented quickly.
We acknowledge the recognition that the Platform-to-Business Regulation (Regulation) is the first step to regulate the platform economy. We appreciate its focus on influencing the contractual terms and bargaining position between the platforms and the business users it hosts. However, transparency and measures of redress are not enough to deal with extraordinary platform power.
eBay welcomes the Commission's intention to adopt an ex-ante regulatory instrument. The creation of the internet has led to the emergence of new economic opportunities and diverse business models. The emergence of online intermediaries, together with the increased availability of information and data, have led to increased consumer choice, access to information and new economic opportunities.
FSB welcomes the opportunity to provide a response to the Commission’s call for evidence on the Digital Services Act package. The Federation of Small Businesses (FSB) is the UK’s leading business organisation. Established over 45 years ago to help our members succeed in business, we are a non-profit making and non-party political organisation that is led by our members, for our members.
The Danish Chmaber of commerce have the following input and suggestions: To remain competitive, retailers and wholesalers need a regulatory framework that supports strong European retail and wholesale ecosystems in a digital environment and gives them legal certainty and incentives to invest in robust omnichannel strategies.
BEUC supports the introduction of ex-ante regulation for large online platforms with significant network effects acting as gatekeepers. Regarding the options provided by the Commission in the Roadmap, the chosen option must ensure strong, effective, timely and consistent rules and enforcement in the EU digital single market.
Vimeo, Inc. hereby provides the following feedback in response to the request for consultation for the Digital Services Act. Vimeo operates the Vimeo video-sharing service, which allows customers throughout the EU, including individuals, businesses, and organizations to upload, share, and view videos.
CCIA appreciates the Inception Impact Assessment’s ("IIA") acknowledgement of the “wide consensus concerning the benefits for consumers and innovation, and a wide-range of efficiencies, brought about by online platforms in the European Union’s internal market.” Nevertheless, CCIA agrees that there is a need for action at the EU level to safeguard an effectively functioning digital single market from the risk of…
EUROCITIES welcomes the proposal for an ex-ante regulatory instrument for large online platforms. The problem description correctly outlines several key challenges in relation to online platforms with significant network effects. Cities are innovation ecosystems and bring together governments, researchers, businesses, and citizens to drive digital transformation at the local level and across the EU.
Libraries have seen the evolution of digital tools for several decades. Like many cultural institutions, they have implemented digital strategies to promote and publicize their collection among their users and beyond, in particular through social networks.
30 June 2020 The EU Digital Services Act ITI Views on the Inception Impact Assessments: Responsibilities, Gatekeepers Regulation and Competition tools The Information Technology Industry Council (ITI) appreciates the opportunity to comment on the European Commission inception impact assessments and roadmaps on clarifying responsibilities for digital services, regulatory instruments for gatekeepers, and the new…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The European Data Centre Association (EUDCA) represents the European data centre (DC) operators community. EUDCA is pleased to submit commentary to this consultation, along the following lines: • EUDCA welcomes the initiative to create regulations across the 27 member states in lieu of leaving decisions to individual states, which would lead to a fragmented regulatory landscape.
YELP’S RESPONSE TO THE ROADMAP - DIGITAL SERVICES ACT PACKAGE: EX ANTE REGULATORY INSTRUMENT OF VERY LARGE ONLINE PLATFORMS ACTING AS GATEKEEPERS I. Introduction Yelp welcomes the opportunity to submit views on the policy options regarding the adoption of an ex ante regulatory instrument for large online platforms with significant network effects acting as gatekeepers in the EU internal market.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The ESSTE, a hub for the gathering of hundreds of different actors of different origins that share online content and services, is the best way to raise public awareness of the challenges of economic development of publishers and digital regulation.
Filed in French · English published by the European Commission
We are very well aware of the unequal conditions European companies face in national, EU and global market due to the growing power of a small number of large platforms, and their network effects. Thus, we fully agree with the EC’s findings and the need to undertake necessary measures to ensure fair competition and real consumer choice, prevent self-preferencing of the dominant global platforms and increase…
Considerations on digital platforms in the context of the new Digital Services Act 1. Definition. “Digital platforms” is a rather ill-defined term that describes all online spaces where users engage in commercial and non-commercial interaction with each other (Gillespie, The politics of ‘platforms’, New Media & Society, 2010).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Developers Alliance welcomes the opportunity to provide its feedback on the IIA on ex-ante regulation for large online platforms, as part of the Digital Services Act package. Software developers, like other entrepreneurs, need a predictable regulatory environment. The proposed regulatory initiative raises concerns from this perspective.
Danish Automotive Service Association (DASA) is in line with FNA on this feedback. We shall especially stress the following based on the need for complete transparancy with theese platforms. Advanced technologies win the automotive industry: on the one hand, the electric car revolutionizes maintenance methods; on the other hand, the increasing connectivity of new "smart" vehicles tends to channel diagnostic…
Platforms leading to imbalances 1. FNA supports the European Commission analysis, i.e. “traditional businesses are increasingly dependent on a limited number of large online platforms. This leads to imbalances in the bargaining power between large online platforms on the one hand and their users and rivals on the other, a trend which is expected to increase in the future.” 2.
As an independent academic, I welcome the opportunity to provide feedback on the Ex Ante Regulatory Instrument (the ‘Instrument). In accordance with the ASCOLA declaration of ethics, I am happy to clarify that I have nothing to disclose. There is a range of options considered in the Inception Impact Assessment (‘IIA’).
Please find attached comments of ACT | The App Association (Transparency Reg. # 7202951387754) on the European Commission’s Inception Impact Assessment, “Digital Services Act package: Ex ante regulatory instrument for large online platforms with significant network effects acting as gate-keepers in the European Union’s internal market” (Ref.
Open-Xchange, as the leading European open source software company in the email and DNS space, commends and supports the Commission's effort to address the gatekeeping power of big Internet platforms and the threat it poses to competition, digital sovereignty and individual rights.
ACT agrees that the Platform-to-Business Regulation was a welcome first step towards achieving a level playing field. A starting point that needs to be further complemented, particularly in light of the impact of the COVID-19 crisis and the potential for future measures to support the recovery process.
Orange response to the Inception Impact Assessment - DSA Package Ex ante regulatory instrument for large online platforms with significant network effects acting as gate-keepers. Orange welcomes the EC initiative to ensure that “large online platforms that benefit from significant network effects remain fair and contestable, in particular in situations where such platforms may act as gatekeepers”.
In this paper, eu travel tech sets out its initial views on the Digital Services Act package, in particular on the ex ante regulatory instrument for large online platforms with significant network effects acting as gate-keepers, based on the European Commission Inception Impact Assessment.
The proposal for a new Ex ante regulatory instrument for large online platforms draws on a vaguely-identified problem, relies on a dubious theory of harm, and proposes an all-encompassing solution whose risks seem far larger than the potential benefits.
EX ANTE REGULATORY INSTRUMENT FOR LARGE ONLINE PLATFORMS Feedback of the Federation of German Consumer Organisations (vzbv) on the Digital Services Act package “Ex ante regulatory instrument for large online platforms with significant network effects acting as gate -keepers in the European Union’s internal market” June 29, 2020 Impressum Verbraucherzentrale Bundesverband e.V.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Danish Government welcomes the Commission’s decision to launch an impact assessment and a thorough public hearing. Since these are complicated topics, it is important to understand, in as much detail as pos-sible, the problems that the proposed instruments aim to address.
The Future Shaping Media Company Limited of The United Kingdom backs the general initiative of the European Commission to update and improve regulations on digital services (Digital Service Act package). As an innovative digital start-up that provides a Fintech, Rightstech, SaaS for digital services we are just one of the 10,000 plus online platforms that are potentially hampered in scaling by the current market…
ARD: 6774178922-55 ZDF: 3209361971-85 June 2020 Digital Services Act Package: Ex ante regulatory instrument for large online platforms with significant network effects acting as gate-keepers in the European Union’s Internal Market Comments on the inception impact assessment ARD and ZDF welcome the opportunity to comment on the inception impact assessment regarding the ex-ante regulatory instrument for large online…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The main benefits of the date economy in the economic and social system, whose applications have proved to be essential in many areas, including in the resilience to Coid-19 (health, infrastructure, etc.), have also highlighted potential critical and risk factors, in particular concerning the gatekeeper role of online platforms.
Filed in Italian · English published by the European Commission
The Ministry of Economic Affairs, Innovation, Digitalisation and Energy of the State of North Rhine-Westphalia supports the general initiative of the European Commission to modernise regulations on digital services (Digital Service Act package).
Filed in German · English published by the European Commission
Juin 2020 Commentaires du Groupe La Poste sur la feuille de route de la Commission européenne sur la régulation ex ante des grandes plateformes numériques dans le cadre du paquet « Digital Services Act » La Commission européenne a publié, le 2 juin 2020, deux feuilles de route concernant le paquet « Digital Services Act » dont une ayant trait à une éventuelle régulation ex ante des plateformes numériques dotées d’un…
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
A small number of very large online platforms operated by US Internet companies have a significant impact on the European economy. The time when data protection and privacy were the only problems of such platforms is long gone. Today it's about a lot more, it's about EU jobs and dependencies.
Online platforms have become paragons of the digital economy. Unfortunately, Europe and European companies have not been at the forefront of the platform transition. This is due to many reasons, one being the sluggish development of the Single Market for digital services, which has not enabled blitz scaling across national borders for the innovative European startups and SMEs.
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.
