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.
For more information and access to the full analysis, please click on “Access the full content” - or on “Request Access”, in case you are not subscribed to our European Digital Economy service.
more news
25 February 26
Protection of minors: overview of national initiatives on banning access to social media
Our latest benchmark shows that an increasing number of European countries are discussing a potential social media ban on children.
23 February 26
The DNA explained: universal service to serve the same goals under a revised approach
Cullen International is issuing a series of analyses on different aspects of the Digital Networks Act (DNA) proposal. This report covers universal service.
20 February 26
Revised Cybersecurity Act (CSA2) - Changes to the EU cybersecurity certification framework
Cullen International published an analysis of the proposed changes to the EU cybersecurity certification framework under the draft Cybersecurity Act 2 (CSA2) delivered by the European Commission on 20 January 2026.