[Home](/)/[Resources](/resources)/EU Digital Markets Act Hardware EU/CEPlatform guide # EU Digital Markets Act: What Hardware Companies Need to Know The Digital Markets Act designates large platform operators as gatekeepers and imposes interoperability, fair access, and data portability obligations on them — creating new rights for hardware makers that depend on those platforms. Understanding what gatekeepers are now prohibited from requiring, and what they must provide, directly shapes OS integration deals, app store relationships, and hardware feature access negotiations for any device sold in the EU. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Feu-digital-markets-act-hardware) At a glance Regulation (EU) 2022/1925 Gatekeeper threshold €7.5B EU turnover + users Enforcer European Commission Max penalty 10% global turnover ## DMA and the hardware supply chain ### What the DMA regulates and who is a gatekeeper The Digital Markets Act (Regulation (EU) 2022/1925) designates large platform operators as 'gatekeepers' and imposes specific obligations on them. Gatekeeper thresholds are: €7.5B annual EU turnover (or €75B market cap), 45M monthly active EU users, and 10,000 active EU business users — all three criteria met in three of the last four years. The European Commission designates gatekeepers and the current list includes major OS, app store, browser, and messaging platforms. ### Hardware companies as business users — not gatekeepers Most hardware companies are affected by the DMA as business users of gatekeeper platforms, not as gatekeepers themselves. If you sell devices pre-loaded with a gatekeeper's OS, integrate with a gatekeeper's app store, or rely on a gatekeeper's payment system or search service, DMA obligations on the gatekeeper create new rights and options for your business — including the right to sideload apps, use alternative payment systems, and access platform interoperability APIs. ### Interoperability obligations and hardware design Gatekeepers operating messaging services (WhatsApp, Messenger) must open interoperability to third-party messaging apps. Gatekeepers operating OSs must allow third-party app stores and sideloading. For hardware makers building connected devices — smart home hubs, wearables, IoT gateways — these obligations change what software environments you can integrate with, what pre-installation deals look like, and how exclusive bundling arrangements with gatekeeper platforms may need to be renegotiated. ### When hardware makers could themselves become gatekeepers A hardware company that operates a connected platform with significant user numbers — a smart home ecosystem, a gaming platform, or a wearable OS — could theoretically reach gatekeeper thresholds in the future. The DMA's core services include 'operating systems' and 'online intermediation services', which could capture large device OS platforms. Companies approaching gatekeeper thresholds should monitor their EU metrics and seek legal advice before notifying the Commission. ## What hardware makers should do 01 Identify which gatekeepers your product or supply chain depends on — look at OS providers, app distribution channels, built-in services, and any pre-installation agreements with platform operators. 02 Review how DMA obligations on those gatekeepers affect your current agreements: pre-installation exclusivity clauses, most-favoured-nation terms, mandatory app bundling, and access to ranking or interoperability APIs are all areas the DMA directly restricts gatekeepers from imposing. 03 Assess whether DMA interoperability obligations create new integration opportunities — for example, third-party app stores or alternative payment processors that you can now include on pre-installed device software without gatekeeper veto. 04 Review data access rights: gatekeepers must provide business users with access to the data generated by their users' interactions on the platform; evaluate whether this data access changes your analytics, product personalisation, or CRM strategy for EU markets. 05 Monitor Commission enforcement: DMA non-compliance by a gatekeeper results in fines and remedies. Where a gatekeeper's non-compliance is affecting your business (e.g., not opening interoperability as required), you have the right to complain to the Commission. 06 If your own connected platform is growing toward gatekeeper thresholds (€7.5B EU turnover, 45M EU monthly users, 10,000 EU business users), seek legal advice on notification obligations and DMA compliance programme design. 07 Keep commercial contracts with gatekeeper platforms under regular legal review — DMA obligations on gatekeepers change what they are permitted to require, and contracts that were standard practice before DMA may now be unenforceable or challengeable. ## Frequently asked questions ### Does the DMA require hardware makers to do anything by a specific deadline? The DMA's obligations fall primarily on designated gatekeepers. Hardware makers as business users have no direct compliance deadline — but they benefit from rights that gatekeepers must deliver from their own compliance dates (which began in March 2024 for initially designated gatekeepers). Hardware makers should review their gatekeeper-dependent relationships to understand which restrictions have lifted and which new integration options are now available. ### Can a hardware company negotiate different terms from a gatekeeper now? Yes — DMA obligations on gatekeepers are not merely aspirational. A gatekeeper cannot condition your access to their platform on mandatory pre-installation of their apps to the exclusion of alternatives; cannot require you to use their in-app payment system exclusively; and must provide access to hardware features (NFC, GPS, Bluetooth) on fair, reasonable, and non-discriminatory terms. If a gatekeeper is imposing terms that contradict these obligations, you have grounds to renegotiate or complain to the Commission. ### Which platforms have been designated as gatekeepers? The European Commission has designated gatekeepers including Alphabet (Google Search, Google Maps, Google Play, Android, Chrome, YouTube, Google Shopping), Apple (App Store, iOS/iPadOS, Safari), Meta (Facebook, Instagram, WhatsApp, Messenger), Microsoft (LinkedIn, Windows PC OS), Amazon (Amazon Marketplace), TikTok (ByteDance), and Booking.com. The list evolves as the Commission makes new designation decisions — check the Commission's DMA designations page for current status. ### What is the penalty for a gatekeeper that fails to comply? Gatekeepers that fail to comply with DMA obligations face fines of up to 10% of global annual turnover, or 20% for repeat infringements. Systematic non-compliance over three years can trigger structural remedies including divestiture. These are enforced by the European Commission directly — not by national competition authorities. **Disclaimer:** Educational resource only. DMA obligations are evolving as the Commission issues guidance and enforcement decisions. Consult a qualified EU competition or technology law specialist for product-specific analysis. 🇪🇺 CE Marking roadmap for your product Every standard, document, and test that applies — free, no account required. See your free roadmap[ Want an expert to take your product through 🇪🇺 CE Marking compliance for you? One consultant from Krono's compliance team takes your product from requirements to legal sale, with a fixed quote before any work starts. See compliance services](/services) Related guides * [EU Accessibility Act HardwareEU Accessibility Act (EAA) for hardware: product accessibility requirements under Directive 2019/882, functional accessibility criteria, conformity assessment, and the 2025 deadline for placing products on the EU market.](/guides/eu-accessibility-act-hardware) * [EU Cyber Resilience ActEU Cyber Resilience Act for hardware: default-secure requirements, vulnerability disclosure, 24-hour incident notification, and the four Annex I product classes.](/guides/eu-cyber-resilience-act) * [EU AI Act HardwareEU AI Act implications for hardware makers: high-risk AI system classification, notified body conformity assessment, CE marking, and embedded AI component obligations.](/guides/eu-artificial-intelligence-act-hardware) * [CE Certification for IoT DevicesComplete CE compliance guide for IoT devices: RED, EMC, RoHS, GPSR, and cybersecurity requirements for connected products enter…](/guides/ce-certification-for-iot-devices)