EU Commission opens proceedings to aid Google in complying with the Digital Markets Act
The question
Why has the European Commission initiated specification proceedings to assist Google in complying with the Digital Markets Act (DMA)?
The key takeaway
The European Commission is showing increased focus on ensuring fair competition between AI developers. This includes close monitoring of compliance with provisions in the DMA which require large platforms to share knowledge and resources with third parties.
The background
The DMA imposes requirements on large online platforms known as "gatekeepers" to regulate fairness and encourage competition in the digital market. Under the DMA, the European Commission can commence "specification proceedings" as a procedure by which the Commission can clarify how a gatekeeper must comply with its legal obligations.
Google was designated as a gatekeeper platform by the European Commission on 6 September 2023 and has been required to comply with the provisions of the DMA since 7 March 2024.
The development
On 27 January 2026, the European Commission announced that it had opened two sets of specification proceedings to assist Google to comply with its regulatory obligations under the DMA. These proceedings concern the obligation for Google to:
- make available, at no cost, interoperability tools that allow third-party developers to access and use hardware and software features of the Google’s Android operating system, particularly those used by Google’s AI services, including Gemini
- allow third-party online search engine providers access to anonymised ranking, query, click and view data held by Google Search on "fair, reasonable and non-discriminatory" (FRAND) terms.
The proceedings are scheduled to last for six months, with preliminary findings communicated to Google within three months and non-confidential summaries of those findings to be subsequently made available to third parties. The proceedings will not make a determination on Google's compliance with the DMA.
Why is this important?
The proceedings are significant because they will test how the DMA’s interoperability requirements apply in practice to AI-related services. They will also help clarify how the DMA’s data access obligations extend to search engine data and shed further light on the anonymisation standards and “FRAND” terms the Commission considers appropriate.
Although the Commission cannot allege non-compliance through specification proceedings, these processes are likely to shape future enforcement action.
More generally, these proceedings evidence increased concern from the European Commission regarding competition in the digital sector with the rapid development of AI. There are similarities between these proceedings and the guidance that the Commission gave to Apple in 2024 to provide competitors easy interoperability with Apple's systems. The parallels with the Apple guidance also highlight the Commission's willingness to use the DMA as a tool to ensure fair competition in digital markets.
Any practical tips?
Gatekeepers and other large online platforms should monitor these proceedings closely, as they are likely to influence how the DMA’s interoperability and data-access obligations are interpreted and enforced in practice. Platforms may also wish to assess whether to proactively develop and publish interoperability tools and to make them available to third-party developers.
Spring 2026
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