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Europe’s Big Tech Crackdown Under the DSA and DMA

Europe’s Big Tech Crackdown Under the DSA and DMA

Fines on Google and Elon Musk’s X test EU digital sovereignty, reshape platform behavior, and strain trans-Atlantic ties

Overview

The European Union is in the middle of an unprecedented crackdown on Big Tech, using a new arsenal of digital laws — the Digital Services Act (DSA), the Digital Markets Act (DMA) and long‑standing competition and privacy rules — to challenge the power and business models of U.S.-based tech giants. Since 2023, Brussels has designated six major platforms as “gatekeepers,” imposed structural obligations on their core services, and begun opening formal proceedings against firms like X, Google, Apple and Meta over monopolistic conduct, opaque algorithms, deceptive interface design and failures to police harmful content.

By late 2025, this framework translated into a cascade of enforcement actions: a €500 million DMA fine for Apple and €200 million for Meta in April, a €2.95 billion antitrust penalty against Google’s adtech business in September, and the first DSA non‑compliance fine — €120 million — against Elon Musk’s X in December, even as the Trump administration linked EU digital rules to steel tariffs and threatened retaliation. These moves signal that the EU intends to entrench its role as a global rule‑setter for digital markets, while forcing concrete changes to platform design, advertising, data practices and AI deployment — and accepting a higher level of geopolitical friction with Washington and powerful CEOs in the process.

Key Indicators

€2.95B
Adtech fine imposed on Google by the European Commission (Sept 2025)
Penalty for abusing a dominant position in online advertising technology and self‑preferencing its AdX exchange, one of the largest single EU competition fines to date.
€120M
First Digital Services Act fine against X (Dec 2025)
Sanction for deceptive blue‑check design, inadequate ad transparency and blocking researcher access to public data — the DSA’s first non‑compliance decision against a very large platform.
€700M
Combined DMA fines against Apple and Meta (Apr 2025)
€500M against Apple over App Store steering and sideloading restrictions, and €200M against Meta over its ‘pay‑or‑consent’ ads model, marking the first sanctions directly under the DMA.
€1.2B
Record GDPR fine against Meta over EU–US data transfers (May 2023)
Largest privacy fine in EU history, ordering Meta to stop sending Facebook user data to the U.S. under mechanisms deemed insufficiently protective, illustrating the bloc’s willingness to impose massive penalties on U.S. tech firms.

People Involved

Teresa Ribera
Teresa Ribera
EU Executive Vice-President and Competition Commissioner (Antitrust Chief) (Leading EU competition and DMA enforcement against major platforms)
Henna Virkkunen
Henna Virkkunen
EU Executive Vice-President for Tech Sovereignty, Security and Democracy (Overseeing DSA enforcement and first non‑compliance decision against X)
Elon Musk
Elon Musk
Owner of X and CEO of X Holdings / xAI (Platform fined under the DSA; publicly attacking EU regulators and weighing legal appeals)
Donald Trump
Donald Trump
President of the United States (Threatening trade retaliation and legal action over EU tech enforcement)
Marco Rubio
Marco Rubio
U.S. Secretary of State (Leading diplomatic pushback against EU tech enforcement)
J.D. Vance
J.D. Vance
Vice President of the United States (Framing EU digital rules as censorship and attack on free speech)

Organizations Involved

European Commission
European Commission
EU Executive
Status: Designing and enforcing the EU’s digital rulebook (DSA, DMA, antitrust and GDPR)

The European Commission is the EU’s executive arm, responsible for proposing legislation, enforcing EU law and managing policies including the digital single market.

X (formerly Twitter)
X (formerly Twitter)
Corporation
Status: Under DSA enforcement, facing fines and ongoing investigations

X is a global social media platform that provides microblogging, live conversation and recommendation feeds, designated by the EU as a Very Large Online Platform under the DSA.

Alphabet / Google
Alphabet / Google
Corporation
Status: Facing record adtech fine and DMA scrutiny in the EU

Alphabet is a global technology conglomerate whose subsidiary Google dominates search, online advertising and Android mobile ecosystems, and is designated a DMA gatekeeper in the EU.

Apple
Apple
Platform Owner
Status: Appealing DMA fine and adjusting iOS/App Store rules for EU users

Apple is a global technology company whose iOS ecosystem, App Store and payment systems have been targeted by the DMA and EU competition policy.

Meta Platforms
Meta Platforms
Corporation
Status: Subject to GDPR, DMA and fresh antitrust probes over data and AI policies

Meta is a social media and technology company operating Facebook, Instagram and WhatsApp, heavily scrutinized by EU privacy and competition regulators.

Trump Administration (United States Government)
Trump Administration (United States Government)
Government Body
Status: Challenging EU digital rules via diplomatic pressure and trade threats

The Trump administration is the U.S. federal executive, using trade and diplomatic tools to defend U.S. tech firms against EU regulation.

Timeline

  1. Europe presses ahead with Big Tech crackdown despite Trump threats

    Analysis

    A Reuters analysis notes that the X fine follows the Google adtech penalty and that the Commission is also probing Meta’s WhatsApp AI policy, concluding that the EU is pressing ahead with its digital enforcement wave despite U.S. pressure and trade risks.

  2. Trump administration denounces X fine as attack on U.S. tech and free speech

    Public Statement

    U.S. officials including Vice President J.D. Vance, Secretary of State Marco Rubio and FCC Chair Brendan Carr blast the X fine as an attack on American companies for refusing to censor content, while Commerce Secretary Howard Lutnick accuses the DSA of being designed to stifle free speech. Musk publicly thanks them.

  3. Commission fines X €120M in first DSA non-compliance decision

    Legal Action

    The Commission finds X in breach of DSA transparency rules and imposes a €120M fine for deceptive blue‑check design, ad repository shortcomings and blocking researcher access to public data, giving the platform 60–90 days to implement fixes.

  4. Ireland opens new DSA probes into TikTok and LinkedIn

    Investigation

    Ireland’s media regulator, acting as a key DSA authority, launches investigations into TikTok and LinkedIn over child‑safety reporting tools, underscoring that enforcement is not limited to U.S. household names and that member‑state regulators also wield significant fining powers.

  5. DSA fully in force for all platforms, with Commission–national co-enforcement

    Implementation

    The Commission highlights that as of February 17, 2024 the DSA applies to all platforms (not only very large ones), with enforcement shared between Brussels and national Digital Services Coordinators, cementing the legal basis for further actions against Big Tech.

  6. Commission fines Google €2.95B over adtech dominance

    Legal Action

    Following a four‑year probe, the EU fines Google nearly €3B for abusing its dominant position in advertising technology by self‑preferencing its AdX exchange and publisher ad server, and demands proposals to resolve conflicts of interest, amid rising trade tensions with Washington.

  7. Socialists & Democrats warn Commission not to bow to Trump over Google fine

    Political Pushback

    After reports that the Commission postponed announcing a Google adtech fine, the S&D group blasts any delay due to U.S. intimidation as unacceptable and insists that Google should be fined or even broken up if found in breach.

  8. EU issues first DMA enforcement fines against Apple and Meta

    Legal Action

    The Commission fines Apple €500M for restricting app developers from steering users to cheaper offers outside the App Store, and Meta €200M for its ‘pay‑or‑consent’ ads model, signaling it will actively enforce the DMA despite U.S. threats of retaliation.

  9. Commission escalates information demands to X over moderation and generative AI

    Investigation

    The Commission requests detailed information from X on content moderation resources and mitigation of risks linked to generative AI, warning that incomplete or misleading replies could trigger fines under the DSA.

  10. Commission opens first formal DSA infringement proceedings against X

    Investigation

    Brussels opens formal proceedings to assess whether X breaches the DSA in areas including illegal content, disinformation, dark patterns (notably blue checkmarks), ad transparency and researcher data access, marking the first DSA case against a very large platform.

  11. Commission designates six Big Tech ‘gatekeepers’ under the DMA

    Regulatory Decision

    Alphabet, Amazon, Apple, ByteDance, Meta and Microsoft are formally designated as gatekeepers for 22 core platform services, triggering a six‑month compliance deadline for DMA obligations.

  12. Digital Markets Act begins to apply to digital gatekeepers

    Regulation

    Following entry into force in late 2022, the DMA starts to apply in May 2023, introducing ex‑ante obligations for large platforms that act as essential gateways between businesses and consumers.

  13. European Parliament adopts landmark DSA rules

    Policy

    The Parliament approves the DSA, setting out obligations for online intermediaries and very large platforms on transparency, content moderation, ads and systemic risk management, with application dates starting in 2023–2024.

  14. European Commission proposes the Digital Services Act and Digital Markets Act

    Policy

    The Commission unveils the DSA and DMA as part of its ‘Shaping Europe’s Digital Future’ strategy, aiming to tackle illegal content, systemic online risks and gatekeeper power in digital markets.

Scenarios

1

Full-spectrum EU enforcement entrenches DSA/DMA as global standards

Discussed by: European Commission officials, EU lawmakers critical of U.S. pressure, competition-law scholars quoted in Reuters and policy think-tank commentary

In this scenario, the Commission doubles down on aggressive enforcement despite Trump’s threats. It rejects weak behavioral remedies from Google and insists on substantial structural changes to the adtech stack if conflicts of interest persist, potentially forcing divestitures or functional separation. Apple and Meta are pushed into further opening their ecosystems and shifting advertising models to comply with the DMA, while X is compelled to redesign verification, recommender systems and transparency tools under close DSA supervision. Other large players such as TikTok, Temu and Shein face similar treatment, spreading compliance costs widely. Over several years, the DSA/DMA framework becomes the de facto global benchmark: third countries emulate key provisions, and multinational platforms adjust product design worldwide to avoid maintaining separate Europe‑only versions.

2

Trans-Atlantic trade clash escalates, forcing calibrated EU compromises

Discussed by: Trade lawyers, S&D Group statements, business press coverage of Trump’s Section 301 threats and tariff linkage

Here, U.S. retaliation moves beyond rhetoric. The administration opens a Section 301 investigation into EU digital regulation and imposes or threatens targeted tariffs or sanctions on EU officials involved in enforcement. This sparks a political backlash in Europe but also fears of a broader trade war among some member states and parts of the Commission. The result is not a repeal of the DSA/DMA, but a more cautious enforcement strategy: timelines slip, fines skew lower, and structural remedies (like breaking up Google’s adtech business) are delayed or converted into negotiated behavioral commitments. National regulators may push harder in privacy (GDPR) and consumer law to maintain pressure while Brussels balances legal rigor and diplomatic risk.

3

Big Tech adapts business models and UI design, blunting the political fight

Discussed by: Platform lawyers, EU competition practitioners, analysts noting firms’ history of incremental compliance

In this outcome, major platforms decide that prolonged confrontation is too costly. Google offers far‑reaching adtech interoperability and data‑separation commitments that satisfy the Commission without a forced sale. Apple restructures App Store and sideloading terms to reduce effective control rents in the EU while preserving its global model. Meta settles its DMA and antitrust disputes by loosening access for rival AI providers on WhatsApp and refining consent mechanisms for ads. X, under investor or lender pressure, tones down anti‑EU rhetoric, overhauls its verification and ad‑transparency tools, and invests more in moderation for the EU market. Political tensions remain, but the story shifts from existential ‘war on Big Tech’ to a technical compliance regime, with the EU claiming victory while U.S. officials quietly move on to other issues.

4

Courts and legal challenges clip the Commission’s wings

Discussed by: Antitrust scholars, some U.S. and EU business lobbies, legal analysis comparing to past Microsoft and Google cases

Under this scenario, companies successfully challenge key parts of DSA/DMA enforcement in EU courts. The General Court and Court of Justice uphold the broad legality of the acts but narrow the scope of certain obligations or strike down especially intrusive remedies, much as U.S. courts curtailed breakup plans in the Microsoft case. Some headline fines are reduced, and the Commission becomes more cautious in pursuing structural measures. The laws remain in force, but their most aggressive applications are curtailed, limiting the EU’s ability to reshape global platform economics and reducing the deterrent effect on future tech giants.

5

Regulation backlash inside Europe softens the next wave of rules (especially on AI)

Discussed by: Certain EU industry groups, political opponents of further tech regulation, commentators worried about innovation and competitiveness

If enforcement produces visible downsides — slower product rollouts, reduced features for EU users, or perceived disadvantages for European startups — a domestic backlash could emerge against additional layers of tech regulation, especially in sensitive areas like AI. Business groups already argue that high compliance costs risk pushing innovation elsewhere. Future legislative efforts (e.g., AI or data‑sharing acts) may be drafted more narrowly, and enforcement of existing rules might tilt toward negotiated solutions rather than high‑profile punishment. This would not undo current DSA/DMA cases, but it could make the 2020s crackdown look like a high‑water mark rather than a permanent baseline.

Historical Context

EU–Microsoft Antitrust Battles over Windows Bundling

1998–2013

What Happened

Beginning in 1998, the European Commission pursued a series of antitrust cases against Microsoft over bundling its media player and later its Internet Explorer browser with Windows, and over interoperability with work‑group server products. In 2004 the Commission fined Microsoft €497M and ordered it to offer a version of Windows without Windows Media Player, followed by additional fines in 2006 and 2008 for non‑compliance, eventually totaling more than €1.6B.

Outcome

Short term: Microsoft paid large fines, was forced to disclose interoperability information and, for a period, offered European users a ‘browser choice’ screen, but its core Windows business remained intact.

Long term: The cases established the EU’s reputation as a tough tech regulator but showed the limits of conduct remedies: the market gradually shifted toward mobile and cloud computing rather than being transformed by the sanctions themselves. The experience informed the EU’s decision to adopt ex‑ante rules like the DMA to address gatekeeper power more systematically.

Why It's Relevant

The Microsoft saga is a precursor to today’s DMA enforcement against Apple, Google and Meta. It demonstrates that while the EU can levy substantial fines and mandate design changes, achieving lasting structural change in digital markets is difficult without more powerful ex‑ante tools — precisely what the DMA and DSA are meant to provide.

GDPR Enforcement Wave Against Big Tech

2018–present

What Happened

After the EU’s General Data Protection Regulation (GDPR) took effect in 2018, privacy regulators, especially in Ireland and France, began imposing major fines on large tech companies. High‑profile cases include a €50M fine against Google by France’s CNIL in 2019 for opaque consent practices and a record €1.2B fine against Meta in 2023 over Facebook’s EU–US data transfers, with orders to suspend such transfers and bring processing into compliance.

Outcome

Short term: Companies faced large but manageable financial penalties and had to re‑engineer consent flows and data‑transfer mechanisms. Some firms localized more data in Europe and invested heavily in compliance teams.

Long term: GDPR became a global reference point, influencing privacy laws from California’s CCPA/CPRA to Brazil’s LGPD, and demonstrating that EU regulation can shape global corporate behavior far beyond the bloc’s borders.

Why It's Relevant

The GDPR experience shows that EU rules can create a de facto global standard despite initial industry pushback. The DSA and DMA may follow a similar path: even if fines on X, Google or Meta are only a fraction of revenues, the need to comply with detailed EU rules could drive product and policy changes that spill over to users worldwide.

United States v. Microsoft: Antitrust Limits on Tech Breakups

1998–2002

What Happened

In the U.S. case United States v. Microsoft, federal and state enforcers sued Microsoft for illegally maintaining a monopoly in PC operating systems by tying Internet Explorer to Windows and excluding rival browsers. A district court initially ordered Microsoft to be broken into two companies, but on appeal the breakup remedy was overturned and the parties settled on conduct remedies requiring API disclosure and oversight rather than structural separation.

Outcome

Short term: Microsoft avoided a breakup but faced years of oversight and some behavioral constraints. Its power in operating systems remained significant, though competition from the web and later mobile eroded its dominance.

Long term: The case shaped modern tech antitrust strategy in the U.S., with courts showing reluctance to impose breakups on fast‑moving digital firms. More recent DOJ actions against Google are again testing whether structural remedies (like divesting Chrome or parts of the ad business) are politically and legally feasible.

Why It's Relevant

This history is relevant to the EU’s current threats to seek structural remedies against Google’s adtech or to order deeper changes for gatekeepers. It suggests that even when regulators talk about breakups, political and judicial constraints often lead to negotiated behavioral fixes. Observers of the EU’s Big Tech crackdown watch these precedents to gauge how far Brussels will actually go if companies resist.