By Ruxandra Popa, Executive Director

On 28 April 2026, the European Commission published its first review of the Digital Markets Act (DMA). The review takes stock of two years of implementation and sets out priorities for the next phase.

CODE supports the DMA’s twin objectives of making digital markets in the EU fairer and more contestable. We welcome this review as an important moment to assess whether the DMA is delivering on its promise. However, we must be clear: the true yardstick by which the DMA should be judged a success is whether European consumers, businesses and innovators are actually benefiting. On this front, while there is some progress, it is moving far too slowly. Indeed, the Commission itself acknowledges that the DMA’s impact is yet to be fully realised. 

As we look toward the next phase, the focus must now intensify on ensuring the benefits of the DMA - opening digital ecosystems, enabling seamless connectivity and interoperable systems, and nurturing an environment of open access - reach the heart of European tech and deliver genuine consumer choice and innovation. In other words, efforts must squarely focus on delivering real-world openness in those areas where there is a solid legal basis, where technical solutions are readily available but progress remains fragile.  

Openness as the guiding principle

The DMA is grounded in a simple idea that sits at the heart of CODE’s work: open digital ecosystems are fundamentally better. They drive innovation, support growth and give European citizens real choice in the devices and services they use.

But for CODE, openness is not just a regulatory ideal; it is the essential oxygen for a new generation of European tech. If we want to see the rise of future-focused European digital champions, they must be able to compete on a level playing field within the ecosystems that currently dominate our lives. We have seen flashes of what is possible—for instance, the Commission notes that alternative browsers like Opera have seen surges in use due to new web browser choice screens. Some of the barriers to switching between Android and iOS are also coming down, bringing interoperability closer. But these remain outliers. For the majority of European SMEs, the "walled gardens" remain as high as ever.

Unfinished business - depth over breadth 

In key sectors such as messaging, wearables and payments, interoperability continues to be delayed, restricted or diluted. Our research shows that consumers care: 82% of European consumers say device interoperability is important, and 91% want smartphones and accessories to work equally well across brands.

Artificial barriers to interoperability come at a real cost: 57% of businesses report higher development and compliance costs due to ongoing compatibility issues. 

In other areas, such as web browser engine choice, compliance on iOS and iPadOS devices has been on paper only.

For this reason, we agree that the priority must remain robust implementation of the rules already in place for core services like operating systems and hardware. We cannot afford to chase new technological horizons while the European digital economy rests on a shaky foundation.

Delivering real‑world impact

The DMA’s success should be measured by its impact in the real world. Opening up closed “walled gardens”, reducing ecosystem lock‑in and enabling genuine interoperability must therefore remain central objectives for the next phase of implementation. In this regard, we agree with the review’s assessment that, if fully implemented, the possibility for providers of connected devices, such as smart watches or ear buds, to access key features of iOS would bring significant gains. CODE strongly supports this important priority and calls for rapid progress. 

Security and privacy concerns must not be used as blanket justifications to block openness. Open systems can be secure, and intellectual property rights should not be weaponised to deny fair access. Any restrictions must be specific, proportionate and backed by clear evidence.

Finally, we were pleased to see the Commission’s commitment to "increase efforts to raise awareness" among potential beneficiaries.This is a critical area for collaboration. CODE’s research shows that 65% of businesses are not even aware that a third-party process exists to help them gain access to operating system functionalities; and among those who are aware, 69% do not believe the current processes established by dominant platforms are sufficiently efficient or transparent. By working together to bridge this gap, we can transform the DMA from a regulatory framework into a practical toolkit for European SMEs and start-ups.

Looking ahead, Europe must focus not only on managing risk, but on supporting growth. The DMA is a vital tool, but it cannot carry Europe’s digital ambitions alone. If Europe wants to lead in innovation, it must build an ecosystem that incentivises and rewards scale and experimentation for new entrants, rather than one that simply manages the dominance of incumbents.