The EU Digital Markets Act and App Stores, One Year On

The EU Digital Markets Act's gatekeeper obligations came into force in March 2024, which means the mobile industry has now had a full year to test the gap between what the law requires on paper and what publishers have actually managed to do with it. That gap is the story. A UA team planning a European link-out strategy needs to know which parts of DMA compliance changed the operating reality and which parts remain a compliance filing that has not yet turned into a working alternative payment flow.

What actually changed under the EU Digital Markets Act for app stores

Apple's response to DMA obligations centres on its alternative business terms, introduced for EU developers: a Core Technology Fee of roughly EUR 0.50 per install above a free threshold, replacing the standard commission model for developers who opt in, alongside the ability to distribute through alternative app marketplaces and to link out to external payment methods without the restrictions that apply elsewhere. Uptake among game publishers has been cautious and uneven, not a wholesale shift. The per-install fee structure creates a genuinely difficult trade-off for high-volume, low-monetising titles, where a flat per-install charge can cost more than the commission it replaces once install volume is large and average revenue per user is modest.

The more visible shift has been in web shop experimentation. Through the early part of the year, publishers including Supercell and King have been testing direct-to-consumer purchase flows for EU users, pointing players to a web-based storefront rather than in-app purchases, a pattern the DMA's anti-steering provisions were specifically designed to enable. This runs in parallel to a similar dynamic playing out in the United States under separate antitrust litigation rather than the DMA itself. For a UA and measurement team the practical effect is the same whichever legal mechanism opened the door: purchase events that used to happen entirely inside a platform's own ecosystem, cleanly attributed through the platform's own SDK, now sometimes happen on a web page the platform does not see at all.

What has not changed, despite the headlines

Worth being precise about what remains unresolved a year in. The DMA has not produced a uniform, low-friction alternative payment experience across gatekeepers. Each platform implemented compliance its own way, with different fee structures, different technical requirements for developers who want to use alternative billing, and different degrees of friction in the actual user checkout flow. A studio operating across multiple gatekeeper platforms in the EU cannot currently build one link-out and payment flow and deploy it everywhere; each integration is closer to a separate project than a shared capability.

Enforcement has also run slower than the initial timeline suggested when obligations took effect. The European Commission has ongoing investigations into whether gatekeepers' implementations meet the law's requirements in substance rather than just in form, and those investigations were still open as of this writing. A UA team building a two-year plan around DMA-enabled web shops should treat the current compliance picture as provisional rather than settled, since enforcement decisions still pending could change what is and is not permitted for specific implementation choices.

The measurement problem nobody solved cleanly

Attribution continuity across the platform-to-web boundary is the operational consequence that has mattered most to UA and measurement teams. A user clicks an ad, installs through the app store, then completes a purchase on a web checkout page the platform does not instrument, and the attribution chain that most MMP setups rely on simply breaks. As covered in this desk's earlier piece "Web Shop Attribution Basics as Link-Outs Go Live in the EU," the practical fixes all demand engineering investment: deep-linked web views with parameter passthrough, server-to-server postbacks from the web checkout back to the MMP, probabilistic modelling for the gap neither method closes. Many mid-size studios have been slow to prioritise that work relative to the size of the EU revenue currently flowing through web checkout.

A checklist for the next compliance change

Given how much of this remains in motion, a European publishing team is better served by a standing checklist than a one-time compliance project:

• Confirm which specific alternative terms each gatekeeper platform you distribute on has actually implemented for your app category, not the terms announced generally, since implementation details vary by app type and region within the EU.
• Model the per-install fee structure against your actual install volume and average revenue per user before opting into any alternative terms, since the break-even point varies sharply by monetisation model.
• Instrument any web checkout flow with server-to-server postbacks to your MMP before launching it, not after, since retrofitting attribution onto an already-live web shop means losing the ability to measure its first weeks of performance.
• Assign one person to track Commission enforcement actions against gatekeeper implementations specifically, since a finding of non-compliance against a platform's current DMA implementation could force another round of changes to the flows your team just built.

What comes next

A year of DMA enforcement has produced more legal and technical complexity than a single clean answer, and that pattern looks set to continue rather than resolve. Ongoing Commission investigations into gatekeeper compliance, alongside further guidance expected on how alternative business terms should look, mean the current setup is a snapshot rather than a destination. Treat every DMA-enabled flow your team builds this year as something that will need revisiting. It is not something to set once and leave alone.

The teams best positioned when another round of guidance lands are the ones already tracking the gap between their compliance filings and their actual working flows today, rather than the ones waiting for a settled legal picture that a year of enforcement history suggests is not coming soon.

Related archive reading

These articles provide related context and remain subject to their stated review status.

• The DMA's First App Store Fees: Apple and Meta Fined
• Apple EU Terms Update: What the DMA Fine Changed