A year ago, European regulators seemed to be on a roll, expecting their new tech antitrust rules to spread Brussels effect-style around the globe. Brussels had begun to issue its first Digital Markets Act (DMA) fines against US “gatekeepers.” The United Kingdom, Japan, and South Korea passed what looked like copycat DMA regulations, and even in the US, the Department of Justice had scored major victories in its antitrust suits against Apple and Google.   

Today, the picture looks quite different. US judges declined to break up Google and rejected charges against Meta. Antitrust champion Gail Slater left her enforcer role in the Department of Justice, though ironically American antitrust cases have brought the biggest changes in the marketplace. The UK, South Korea, and Japan have narrowed the scope of their regulations or stepped away from enforcement. Even in Europe, few see the DMA bringing real change into the marketplace.  

CEPA has updated its Mapping the Brussels Effect project to reflect these changes. 

What changed? Artificial intelligence is upending tech markets, injecting new competition into markets such as Internet search. Governments around the globe, including in Europe, are emphasizing economic growth and competitiveness — and moving away from regulation. At the same time, Washington is applying pressure on governments that it feels discriminate against American tech.   

In South Korea, President Lee Jae-myung has backed away from his campaign promise to introduce platform regulation. A more stringent monopoly regulation bill has been watered down to the Online Platform Fairness Act, but it is still viewed as discriminatory to American firms in Washington. The Lee administration, fearful of damaging Korea’s close trade relationship with the US, has refused to move forward with the Bill.  

Japan is also proceeding cautiously. Its recently implemented Mobile Software Competition Act is much narrower in scope than Europe’s DMA. It targets two companies, Apple and Google, and only on a few issues — primarily app store payments and interoperability.  

After the UK implemented its DMA-inspired Digital Markets, Competition, and Consumers Act, Britain’s top regulatory watchdog designated Google and Apple as having strategic market status, similar to the DMA’s “gatekeeper” designation. British regulators gained broad discretion to draft codes of conduct and force mandatory interoperability against the two US companies. 

But instead of imposing fines or behavioral remedies, last month, UK regulators accepted non-binding commitments. Apple and Google promised to avoid discriminating against third-party apps. The regulators left alone app store fees, which reach up to 30% on the Apple App Store. The agreement “does not imply that Google or Apple have acted anti-competitively,”the Competition and Markets Authority press release explicitly states. A month later, the Chancellor of the Exchequer promised that the “UK would achieve the fastest AI adoption in the G7,” signaling an emphasis on growth over regulation. 

Despite the global shift from imposing stringent antitrust action, Brussels denies it is backing away from the DMA. European Commissioner for Competition Teresa Ribera dismissed the notion that the EU would soften its approach, stating, “sorry, but we’re not going to undo our regulation just because you don’t like” it.  

The Commission has fined Apple €500 million and Meta €200 million for breaching the DMA. It found that Apple blocked developers from distributing their apps outside the App Storeand that Meta’s proposed “consent or pay” model advertising model failed to offer users an option to use less of their personal ads. It also has opened a public consultation on proposed measures to require Google to share its search data with third-party search engines, alleging that its current data restrictions lock in its search market monopoly. A binding decision will be made on July 27. 

Yet it’s unclear how vigorously Brussels will pursue its crackdown. The continent’s new priority is boosting flagging competitiveness. It is pursuing digital simplification and is beginning to doubt whether the DMA has achieved its intended effect of jumpstarting competition in digital markets. Major American tech firms still enjoy dominance. Google controls 87% percent of the European internet search market. Apple and Google hold 95% of the European app store market.  

European officials contend that any type of regulatory enforcement takes time, and the DMA’s impact will be felt over the coming years. The GDPR, Europe’s landmark data privacy framework, was also criticized as slow and ineffective. But by 2026, almost six years after its passage, cumulative GDPR fines have reached €6 billion, with over 2,500 individual fines.  

In contrast to Europe, the US is retreating from vigorous antitrust enforcement. During President Donald Trump’s first administration and the Biden administration, Washington launched a series of cases accusing Google of having an illegal monopoly in search, probing Meta’s purchase of Instagram and WhatsApp, and sung Apple for lack of interoperability on devices.  

Google lost its search monopoly case against the Department of Justice, forcing the firm to hand over some of its data to competitors. Yet the Court stopped short of forcing a sale of Google Chrome, citing the emergence of AI search products as a market disruptor. 

The second Trump administration initially conveyed mixed signals on antitrust. The populist wing of the MAGA movement prioritized reigning in Silicon Valley. 

Antitrust cases continued to be prosecuted by the Department of Justice. US courts arguably have imposed the single biggest change worldwide in digital markets – ordering Apple to stop charging a 30% commission on paid app downloads. Although Apple has appealed to the Supreme Court, a quip making the rounds in Brussels is that the real enforcement of the DMA is taking place across the Atlantic Ocean. 

But another wing of the Trump coalition views US tech as a weapon of global economic dominance. In the White House, David Sacks, chair of the President’s Council of Advisors on Science and Technology and former AI czar, enjoys close relationships with Silicon Valley and pushed for supercharging AI adoption. Administration officials have threatened retaliation against European (and Japanese) regulators if they crack down on US companies.  

As Washington pivots from antitrust enforcer to tech protector, the ‘Brussels Effect’ faces a significant stress test yet. The DMA still could become a global standard – or fade into a regional footnote.  

Jack Galloway is the Program Assistant for the Tech Policy Program at the Center for European Policy Analysis.

William Echikson is a Nonresident Senior Fellow with the Tech Policy Program and editor of the online tech policy journal Bandwidth at the Center for European Policy Analysis (CEPA).

Bandwidth is CEPA’s online journal dedicated to advancing transatlantic cooperation on tech policy. All opinions expressed on Bandwidth are those of the author alone and may not represent those of the institutions they represent or the Center for European Policy Analysis. CEPA maintains a strict intellectual independence policy across all its projects and publications.

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