The UK's Digital Markets Act Equivalent: What the DMCC Act Means for Big Tech

The Competition and Markets Authority didn't wait long to use its new powers. Within a year of the Digital Markets, Competition and Consumers Act 2024 coming into force, the CMA had designated Google with Strategic Market Status in general search and search advertising (October 2025), designated both Google and Apple with Strategic Market Status in their mobile platforms (also October 2025), and — by June 2026 — imposed its first binding conduct requirements on Google covering publisher fairness and data portability. For a regulatory regime widely expected to move cautiously, the pace has been notably quick.

Why the UK built its own version rather than borrowing the EU's

Since Brexit, the UK isn't bound by the EU's Digital Markets Act. Rather than leave a gap, Parliament passed its own regime, run through the CMA's Digital Markets Unit under legislation introduced on 1 January 2025. The structural difference from Brussels is deliberate: where the EU DMA sets a fixed list of obligations that apply automatically once a company is designated a "gatekeeper," the DMCC Act gives the CMA discretion to tailor conduct requirements to each firm's specific business model. UK officials have framed that as more proportionate; critics have called it less predictable for the companies involved. Both are probably true.

Who's actually in scope

Only the very largest platforms qualify. The statutory turnover threshold for Strategic Market Status is more than £1 billion in UK revenue or £25 billion globally — a bar that, as of mid-2026, only Apple and Google have cleared in the CMA's published designations. That means the Act's sharpest tool, the conduct-requirement regime, is currently a two-company story rather than a broad new burden on UK tech generally. CMA chief executive Sarah Cardell signalled as far back as March 2025 that further designation investigations would follow a "roadmap" process of public consultation before any conduct requirements land — which is part of why setting requirements for Apple and Google, both designated in October 2025, has taken until this year to produce binding measures.

What that's produced so far: a publisher conduct requirement for Google, imposed 3 June 2026, followed two weeks later by fair-ranking and data-portability requirements, imposed 17 June 2026. Apple and Google also offered app-store commitments — covering areas like developer access and interoperability — that took effect from 1 April 2026, though these sit outside the Act's formal conduct-requirement mechanism and function more as negotiated undertakings than statutory obligations.

The part that actually touches most UK businesses

Strategic Market Status gets the headlines, but the DMCC Act's consumer-protection provisions apply far more broadly, and they're already being enforced. Since 6 April 2025, the Act has banned drip pricing — showing a headline price and then adding mandatory charges as a customer proceeds through checkout — and fake or incentivised reviews, backed by the CMA's new power to fine companies directly, without going to court first, up to 10% of global annual turnover. A year into that regime, the CMA reported in April 2026 that its enforcement work across drip pricing, fake reviews and manipulative "choice architecture" had already secured £760,000 in consumer refunds and £4.7 million in fines. New subscription-contract rules — requiring clear pre-contract information, renewal reminders, and 14-day cooling-off periods — are due to take effect this year as the next phase of that same regime.

For a UK business that sells to consumers online, regardless of size, that's the part of the DMCC Act worth reviewing now: whether checkout pricing genuinely reflects the full mandatory cost upfront, and whether review collection and display practices could be read as encouraging or permitting fake reviews. The CMA has said its early enforcement focus was on the most clear-cut breaches; the one-year update makes clear that period is over.