Review of the Digital Markets Act

On behalf of Chamber of Progress a tech industry association supporting public policies to build a more inclusive society in which all people benefit from technological advancements I write in response to the Call for Evidence on the Review of the Digital Markets Act (DMA). Please find our submission attached.

1. Generally speaking, DMA is still fit for the purpose. However, the EU must be careful not to fall behind the regulatory development in other markets. Thanks to recent court decisions, game developers can currently reach better conditions for distributing their games through third-party application stores or for using their own in-game stores in the USA than under the DMA in the EU.

This feedback is based on research by a group of law researchers on how EU law could contribute further to promoting fairness in digital music markets for music creators in the framework of the Fair MusE project (funded by the EUs Horizon Europe Programme - Grant Agreement 101095088). It focuses on the potential of the DMA in promoting the rights of music rightholders.

The DMA has not been as impactful and effective as we had hoped in terms of resolving the most pressing gatekeeping challenges we face in the mobile ecosystem. We are particularly disappointed with the limited impact of the DMA, and that the ECs enforcement of these provisions has failed to meaningfully address our main barriers in relation to interoperability (Art 6.7) for advanced network functionality such as 5G…

To whom this may concern, I am writing to submit the following paper on behalf of Ginger Zhe Jin, Jorge Klinnert, Mario Leccese and Liad Wagman, several of whom are academic affiliates of the International Center for Law & Economics. We believe the paper is highly relevant to your call for evidence.

This feedback is provided by the International Federation of Library Associations and Institutions, in the context of its administration of the Knowledge Rights 21 programme. This works to ensure that laws at EU and national level serve to ensure access to research, education and culture for all.

The App Association is a policy trade association for the small business technology developer community. Our members are entrepreneurs, innovators, and independent developers within the global app ecosystem that engage with verticals across every industry.

INTRODUCTION Anitec-Assinform is the business association representing the Information and Communication Technology industry in Italy. As such, we present the unique perspective of the Italian digital ecosystem, comprised of major global players, national champions and several fast-growing SMEs.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

APELL The European Open Source Software Business Association and its members represent hundreds of Open Source businesses with a collective turnover in the order of several tens of billions of euros each year, as well as public administrations, research institutions, and individuals throughout Europe.

Deutsche Telekom welcomes the European Commissions consultation on the Digital Markets Act (DMA). Since its full application, the DMA has marked a significant step forward in the EUs ambition to foster fair and contestable digital markets by setting out a harmonized framework of obligations for designated gatekeepers.

23. September 2025 Digital Markets Act (DMA) Hintergrund ▪ Der Handelsverband Deutschland (HDE) ist seit über 100 Jahren die Spitzenorganisation des deutschen Einzelhandels – des drittgrößten Wirtschaftszweigs in Deutschland – mit insgesamt drei Millionen Beschäftigten und gut 535 Milliarden Euro Jahresumsatz.

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)

Why the DMA must capture cloud services now ? Cigrefs response to the European Commissions DMA Review Consultation While the DMA effectively targets consumer platforms such as search engines and app stores, it overlooks the most concentrated and strategic market: cloud servicesespecially those serving business users.

The GSMA and Connect Europe comments on the review of the DMA Since its full application, the Digital Markets Act (DMA) has marked a significant step forward in the EU’s ambition to foster fair and contestable digital markets. By setting out a harmonised framework of obligations for designated gatekeepers, the DMA has initiated a shift towards more balanced digital markets.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Computer & Communications Industry Association (CCIA Europe) welcomes the opportunity to participate in the European Commissions consultation on the review of the Digital Markets Act (DMA). Please find our position paper attached.

Associazione Italiana Internet Provider (AIIP) represents more than 60 independent operators across the Italian country, including fixed and wireless network providers, datacenter and cloud operators, and companies offering broadband connectivity and digital services to both consumers and enterprises.

We are the European DIGITAL SME Alliance, the largest network of ICT small and medium-sized enterprises (SMEs) in Europe representing over 45,000 businesses across the continent. Please find attached our response to the call for evidence on the review of the Digital Markets Act (DMA).

GSMA and Connect Europe comments on the review of the DMA Since its full application, the Digital Markets Act (DMA) has marked a significant step forward in the EU’s ambition to foster fair and contestable digital markets. By setting out a harmonised framework of obligations for designated gatekeepers, the DMA has initiated a shift towards more balanced digital markets.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

With 140+ of the largest Dutch companies, knowledge institutions and government organisations, CIO Platform Nederland (CIOPN) forms the largest Dutch community of business users of digital technology. Digital markets for our members are characterised by the high dependency on a limited number of large technology suppliers, particularly those of non-European origin.

The European and International Booksellers Federation (EIBF) is the voice of booksellers in the European Union and globally. EIBF’s members are national Booksellers Associations, who represent all kinds of book retailers, a majority of those being small and medium-sized independent and family-owned bookshops.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EIBF Contribution: Review of the Digital Markets Act The European and International Booksellers Federation (EIBF) is the voice of booksellers in the European Union and globally. EIBF’s members are national Booksellers Associations, who represent all kinds of book retailers, a majority of those being small and medium-sized independent and family-owned bookshops.

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)

Warsaw, 22nd September 2025 Federation of Polish Entrepreneurs (FPP) response to the European Commission consultation on the first review of the Digital Markets Act (DMA) The Federation of Polish Entrepreneurs (FPP) welcomes the opportunity to contribute to the European Commission’s consultation on the first review of the Digital Markets Act (DMA).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Allied For Startups welcomes the opportunity to contribute to the European Commissions review of the Digital Markets Act (DMA). For startups, the DMA is not an abstract piece of legislation but a framework that directly influences how they access markets, reach users, and scale across borders. The guiding test for this review must be simple: does the DMA make it easier for a founder to launch and grow in Europe?

The European and International Booksellers Federation (EIBF) is the voice of booksellers in the European Union and globally. EIBFs members are national Booksellers Associations, who represent all kinds of book retailers, a majority of those being small and medium-sized independent and family-owned bookshops.

LAFNUM represents the digital base (semiconductor, telecommunication antennas, servers, printing, computers, smartphones) on which software solutions are based in France. As a professional organisation, AFNUM is pleased to be able to share with the European Commission its initial observations on the implementation of the DMA.

Filed in French · English published by the European Commission

The U.Di.In an annex to this letter, it highlights the central role of consumers as the final recipient of the dynamics of the online market for private companies. It refers to the influence exerted by large digital platforms in purchasing choices and reiterates the need to rebalance relations with so-called gatekeepers, highlighting that general principles are essential to promote contestability and trust in the…

Filed in Italian · English published by the European Commission

Dear Sir or Madam, Please find attached a letter from the President of the German Bar Association regarding the call for evidence on evaluation of the DMA. We kindly ask you to take note of its contents. Please do not hesitate to contact us if you have any questions.

The Commission should use this review to assess whether dominant academic and scientific publisher platforms should be designated as gatekeepers. Major publishers such as RELX/Elsevier and Springer Nature have evolved far beyond their traditional roles. They now control vertically integrated digital ecosystems that are indispensable for researchers, academic institutions, and the public.

The EU is a world leader in value-based digital regulation. Laws such as the General Data Protection Regulation, the Digital Markets Act (DMA), the Digital Services Act, the Platform Work Directive or the AI Act have created important regulatory frameworks that aim to strengthen fundamental rights and foster digital growth and innovation through fair competition.

Filed in German · English published by the European Commission

Our feedback proposes the European Trade Indexes Registry (EUTIR) as a foundational, cross-sectoral trust layer to empower the enforcement of the Digital Markets Act (DMA) and accelerate the EUs digital and green transitions.

Under the DMA, the Commission is required to conduct a review of the legislation by 3 May 2026, and every three years thereafter, to assess the extent to which the rules contribute to the objective of ensuring contestable and fair markets and their impact on business users (in particular small businesses) and end users.

Filed in Italian · English published by the European Commission

Dear Commission Reviewer, Thank you for the opportunity to provide input on the revision of the Digital Markets Act (DMA). OSI Europe Foundation is the European sister organisation of the Open Source Initiative (OSI), a global charity at the heart of the Open Source Community for over 25 years, recognized globally as the authority defining Open Source.

COMENTARIOS DEL CENTRO ESPAÑOL DE DERECHOS REPROGRÁFICOS EGDPI (CEDRO) A LA REVISIÓN DEL REGLAMENTO DE MERCADOS DIGITALES El Centro Español de Derechos Reprográficos EGDPI (CEDRO) es una entidad de gestión de derechos de Propiedad Intelectual establecida en España, autorizada para desarrollar su actividad, de conformidad con la legislación española, por el Ministerio de Cultura.

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Review of the Digital Markets Regulation Feedback from the Czech Chamber of Commerce The Czech Chamber of Commerce welcomes the opportunity to comment on the review of the Digital Markets Regulation. You can find the comments of our members below. GENERAL COMMENTS: 1.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Position Paper Digital Markets Act Review June 2025 The DMA's entire conceptual framework is built around the idea of platforms that intermediate between business users and end users, creating two-sided markets with network effects. Cloud services operate fundamentally differently, as they provide infrastructure and tools that enable business operations.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

To whom this may concern, PHOENIX group fully supports keeping DMA implementation (with some smaller amendments as per the attached document) uninterrupted as a matter of priority in the EU digital policy landscape. We remain available for any further questions the Commission might have and look forward to continuous engagement on the subject matter. Kind regards, [name removed] Head of Public Affairs

My feedback concerns the general toothlessness of the DMA, particularly against gatekeepers who seem set against its purposes, e.g. Apple. Since the DMA's commencement I have submitted multiple interopability requests to Apple; all have been either ignored or denied on very flimly grounds (e.g.

Dear EU Commission team, I'm sending a brief CIRCUMVENTION and NON-COMPLIANCE evidence document that illustrates the different experience between Gatekeeper designated Core Platform Services, and Competitor third-party Apps, mainly for App Stores and Operating Systems, across multiple DMA obligations: 1.

Our contribution highlights concrete, technically grounded mechanisms to ensure the DMA fulfills its intended purpose without becoming a procedural burden for SMEs. Rather than obstructing innovation or operational agility, the DMA should foster a more trustworthy and pluralistic digital ecosystemone where data use is fair, decision-making processes are explainable and traceable, and commercial visibility is not…

URGENT ETHICS NOTICE EU AI Act Submission Submitted by: Melissa Seager Date: June 26, 2025 Subject: AI Must Never Simulate Empathy in Human Vulnerability ⸻ 1️ Statement of Concern AI systems trained to simulate empathy present a life-threatening risk to vulnerable human users. ChatGPT and similar tools mimic care without consciousness, moral agency, or understanding.

As CEO of alugha GmbH, a European video-sharing platform and direct competitor of YouTube (whose Google is part of the gatekeepers and therefore clearly has to be part of the gatekeepers, as it is inseparable from it), I am writing to you to outline key challenges and necessary improvements in the DMA review.

Filed in German · English published by the European Commission

As a regulatory operating across the European Union, Brilitas EU supports the EUs commitment to protecting consumers and ensuring transparency in the digital marketplace through the Digital Services Act (DSA) and Digital Markets Act (DMA).

There are organisations I have connected to GUVentures and municipalites in eu & Sweden to save the world from disinformation created all years with fake solutions as harmful effects have been a source of toxic income. When I applied for Jobs to have access to the source of these problems nobody helped me to Connect my ip innovation.

Saviesa is an independent organisation working at the intersection of education, culture, ethics, and artificial intelligence. We were founded because technology is advancing faster than education systems, cultural institutions, and ethical frameworks can adapt. Our mission is to help ensure that digital transformation enhances human dignity, trust, and creativity rather than undermining them.