The Digital Markets, Competition and Consumers Act received Royal Assent in May 2024, but its real teeth are now biting. With the Competition and Markets Authority actively designating firms as having Strategic Market Status, and the first wave of conduct requirements being set, UK businesses that depend on dominant tech platforms are facing a genuinely altered landscape. Whether you sell through Apple’s App Store, run infrastructure on AWS or Azure, or fund growth through Google’s ad network, the DMCC Act implications for UK businesses are concrete and, in some cases, commercially significant.
This is not abstract regulation. It is targeted legislation designed to shift negotiating power away from a small group of platforms and towards the businesses that depend on them. Understanding what has changed and how to respond is now a practical business priority.
What the DMCC Act Actually Does
The Act creates a new regulatory framework, administered by the CMA, that allows the regulator to designate certain large digital firms as having Strategic Market Status, or SMS. This designation applies to companies whose market position is so entrenched that ordinary competition mechanisms are not working. Once designated, a firm is subject to tailored conduct requirements that restrict how it can behave towards dependent businesses.
The types of conduct being addressed include self-preferencing (where a platform promotes its own services over third-party alternatives), restrictive default settings, and unfair terms imposed on businesses that have little choice but to accept them. For businesses on the receiving end of these practices, the Act gives the CMA new powers to intervene and impose remedies without needing to wait years for a full market investigation.
You can read the CMA’s own summary of its digital markets powers at gov.uk, which lays out how it intends to use this legislation in practice.
App Stores: The Clearest Battleground
If your business distributes software through the Apple App Store or Google Play, the DMCC Act is directly relevant. Both Apple and Google are widely expected to receive SMS designation in mobile ecosystems. The CMA has already conducted extensive market studies into mobile platforms, and the investigation findings were damning enough to prompt legislative action.
What this means in practice: conduct requirements could compel app store operators to allow alternative payment systems, reduce commission rates where they are deemed unfair, and improve the transparency of app ranking and review processes. For UK app developers and software businesses, this could represent a meaningful reduction in the 15 to 30 per cent commission they currently pay on in-app purchases, as well as greater freedom to direct customers towards external payment options.
The strategic move here is to document your current dependency. If you have been absorbing platform commission as a cost of doing business, model what a 5 to 10 percentage point reduction would do to your margins. Equally, begin evaluating whether alternative distribution channels, such as progressive web apps or direct-download models, are viable for your product. The Act creates leverage; whether you benefit from it depends on whether you are positioned to use it.
Cloud Providers: Less Obvious, but Important
The cloud infrastructure market is more complex. AWS, Microsoft Azure, and Google Cloud collectively account for the vast majority of UK enterprise cloud spend. The CMA’s 2023 cloud services market study identified concerns around egress fees, technical barriers to switching, and loyalty discounts that effectively lock businesses in. The DMCC Act gives the regulator new tools to address these concerns if the dominant providers receive SMS designation in cloud markets.
For business owners, this is a prompt to audit your cloud contracts now. Many organisations have drifted into deep dependencies on a single provider without a clear rationale. Egress costs alone can make switching prohibitively expensive. If the CMA does move to reduce these barriers, businesses that have already mapped their cloud architecture and identified portability gaps will be better placed to act quickly.
It is also worth noting that the Act strengthens consumer rights more broadly, including around subscription services and automatic renewals. If your business uses cloud-based subscriptions with auto-renewal, the compliance obligations under this part of the Act fall on you as the provider, not just the large platforms.
Ad Networks: Where the Money Gets Complicated
Google’s dominance in digital advertising is well documented. The CMA’s separate investigation into Google’s ad tech stack has been running in parallel with the legislative process, and the DMCC Act hands the regulator more direct intervention powers if conduct requirements are needed. For UK businesses that depend on Google Ads or Meta’s advertising platforms for customer acquisition, the implications are layered.
On one hand, greater platform accountability could mean more transparent auction mechanisms and better data access for advertisers. On the other, if major structural remedies are eventually imposed, the short-term disruption to ad pricing and reach could be significant. Businesses that have built growth models almost entirely on paid social or paid search are exposed to this volatility in a way that those with diversified acquisition channels are not.
The practical response is not to abandon paid advertising, but to treat platform dependency as a business risk that needs managing. Building organic reach, developing owned channels such as email lists, and testing alternative ad platforms are sensible hedges regardless of how the regulatory process unfolds.
Strategic Moves UK Business Owners Should Consider Now
Regulation of this kind creates both risk and opportunity. Here is where I would focus attention.
Map your platform dependencies honestly
Most businesses underestimate how concentrated their dependencies are until they try to calculate what it would cost to switch. Do the exercise properly. List every dominant platform you rely on for distribution, infrastructure, or customer acquisition, and quantify what you pay and what you would lose if terms changed.
Engage with the CMA’s consultation processes
The CMA is actively seeking input from businesses that interact with designated platforms. This is not bureaucratic box-ticking. The conduct requirements imposed on SMS firms will be shaped partly by the evidence the CMA gathers from dependent businesses. If you have a legitimate grievance about platform behaviour, this is the mechanism to raise it.
Revisit contracts and terms of service
The consumer protection elements of the DMCC Act impose new obligations on your business if you sell subscriptions or use drip pricing. Review your checkout flows, subscription terms, and renewal notifications to ensure they meet the new requirements. The Act gives the CMA direct enforcement powers here, and the fines are not trivial.
Treat diversification as infrastructure investment
Reducing platform dependency is not just a regulatory compliance exercise; it is sound commercial strategy. Businesses with multiple distribution channels, diversified ad spend, and portable infrastructure are more resilient regardless of what happens in regulatory proceedings.
The Bigger Picture
The DMCC Act implications for UK businesses are significant precisely because this legislation has real enforcement machinery behind it. The CMA has demonstrated in recent years that it is willing to use its powers aggressively, blocking major deals and imposing substantial remedies. This is not a piece of paper that will sit quietly on a shelf.
For tech-reliant businesses, the message is straightforward: the rules of engagement with dominant platforms are changing, the change is being driven by law rather than goodwill, and the businesses best placed to benefit are those that understand their own dependencies clearly enough to act when conditions shift.
Frequently Asked Questions
What is the DMCC Act and when did it come into force?
The Digital Markets, Competition and Consumers Act received Royal Assent in May 2024 and its digital markets provisions are being brought into force in stages through 2025 and 2026. It gives the CMA new powers to regulate dominant tech platforms through a Strategic Market Status designation process.
Which companies are likely to be designated under the DMCC Act?
The CMA has not yet published a full list of designations, but Apple, Google, Meta, Amazon, and Microsoft are widely expected to be among the first firms to receive Strategic Market Status in relevant markets. Designation is market-specific, so a firm could be designated in one area but not another.
How does the DMCC Act affect small UK businesses that use app stores?
If app store operators receive Strategic Market Status, the CMA could impose conduct requirements around commission rates, payment processing rules, and app ranking transparency. Small developers may ultimately gain more flexibility in how they monetise their apps and direct users to external payment options.
Does the DMCC Act impose any obligations directly on my business as a seller or service provider?
Yes. The consumer protection elements of the Act include new rules on subscription contracts, drip pricing, and fake reviews that apply to businesses selling to UK consumers. If your business uses auto-renewing subscriptions, you will need to review your terms and notification processes to ensure compliance.
What enforcement powers does the CMA have under the DMCC Act?
The CMA can impose fines of up to 10 per cent of global annual turnover on firms that breach conduct requirements or consumer protection provisions. It can also impose interim enforcement orders and accept binding commitments from firms without needing to complete a full investigation, making enforcement considerably faster than under previous legislation.