The UK’s Digital Markets, Competition, and Consumers Act (DMCC Act) establishes an ex ante regime for big tech companies, which is likely to enter into force in October 2024. The DMCC is comparable to but different from the EU Digital Markets Act (DMA).

The key differences include that the DMA favours swift implementation of the rules through a fast-track procedure to designate gatekeepers, with the relevant obligations becoming directly applicable six months after the designation.

By contrast, the UK procedure for designating companies with strategic market status (equivalent to gatekeeper status in the EU) could be lengthier. The CMA must conduct an evidence-based investigation and consult stakeholders.

In addition, in the UK, targeted companies may seek to justify their practices with countervailing benefits (e.g. for users’ privacy and security), which is not possible under the DMA.

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