By Ruxandra Popa, Executive Director

Approaching my first six months with CODE since stepping into the role of Executive Director in February, this feels like a natural moment to take stock of the rapidly moving digital landscape. This first half of the year has been incredibly dynamic. As the European Commission took stock of two years of implementation of the Digital Markets Act (DMA), we have also witnessed a broadening dialogue on the practical realities of digital competition. AI and cloud have taken centre stage as legislators and regulators seek to address rapidly evolving trends in those markets, seeking to reconcile openness and sovereignty and ensure Europe is fit to embrace the AI economy.

In this dynamic environment, CODE has continued to highlight a fundamental truth:  that the measure of success for any regulation is whether European consumers, businesses and innovators are seeing tangible benefits.  A look back at the achievements and ongoing challenges of the past six months of digital regulation and enforcement offers a mixed picture. 

Foundations laid, friction remaining

A central focal point of H1 was the European Commission’s landmark two-year review of the DMA. The review rightly took stock of implementation milestones and early enforcement successes. These include, notably, the ability for consumers to choose their preferred browser and to mix and match devices from different brands without losing access to key functionalities.

At the same time, the review acknowledged a central reality: the DMA’s full impact is yet to be fully realised. Transforming digital ecosystems from theoretical compliance checklists into fair and contestable environments remains an active work in progress.   

Concrete evidence of progress - towards open and secure interoperability  

The good news is that the past six-months have brought several long-awaited collaborative milestones, which serve as clear, real-world proof that breaking down "walled gardens" is entirely achievable without compromising system integrity or consumer safety: 

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• End-to-End Encrypted (E2EE) RCS messaging: The successful cross-platform rollout of end-to-end encrypted RCS messaging between iOS and Android demonstrates that deeply integrated, secure communication across competing service ecosystems is fully viable.  

• Cross-platform file sharing & quick pairing: Progress in seamless file sharing and open quick-pairing protocols aim to demonstrate that device ecosystems can interoperate smoothly, giving consumers the freedom to mix and match accessories regardless of brand.  

These early wins are significant outliers showing what is possible. They also reveal that open digital design does not have to come at a cost to user privacy or device security. It is a  common, persistent misconception in modern tech debates that closed architectures are inherently safer simply because their inner workings remain hidden. With the right safeguards in place, based on common standards developed with industry and security experts, openness and security are fundamentally compatible. 

Not there yet - competition and innovation  

However, for the majority of digital challengers, progress remains fragile. A primary example is the mobile browser space: while choice screens have introduced surface-level visibility, the lack of practical ability to use an alternative browser engine means that true back-end autonomy is still missing on iOS. 

For many consumers and European tech players, the walls enclosing the most restrictive ecosystems remain as high as ever. This is why we feel that, as legislators and regulators increasingly turn their attention to competition challenges in the AI and cloud sectors, effective implementation of the rules already in place for core services like operating systems and hardware must remain a top priority. 

This is equally true in the UK, where the Competition and Markets Authority has made progress towards interoperability for connected devices and browser engine choice key priorities for the second half of 2026. EU and UK users and businesses are equally entitled to benefit from more open and contestable digital markets.

The true cost of artificial barriers

When platforms choose to maintain artificial barriers rather than adopt secure and open architectures, it is European businesses and consumers that pay the price. 

CODE’s recent six-market survey of European manufacturers and developers exposed a significant "translation gap" between legislative intent and market reality.  The data shows that 57% of businesses report that persistent interoperability barriers have directly increased their development and compliance costs. This dynamic amounts to a heavy, structural "innovation tax". 

Smaller startups, SMEs and developers simply do not possess the endless resources required to build clunky, regional variants or fragmented workarounds for their software just to satisfy a gatekeeper's proprietary rules. To scale effectively, they need a predictable environment built on non-discriminatory access where they can write once and run services anywhere.  This also means that regulators need to ensure that any rules or requirements enable, rather than inhibit, the rapid rollout of cutting edge AI technologies. Ultimately, the focus has to be on consumer and market benefits: are Europeans able to securely access, use and create innovative services for all to use?

Our business polling makes the market's mandate clear: 66% of companies want regulators to actively promote common, open industry standards. By aligning competition rules with collaborative standardisation, industry and policymakers can design a thriving and resilient digital economy.  

As we head into the second half of 2026, CODE will continue to advocate for real-world openness to remain the core principle guiding our compliance frameworks, and for a transparent, practical framework that eliminates artificial lock-in and fosters competition on technical merit. This is the surest path to innovation, growth, competitiveness, resilience and sovereignty.