2024 was a significant moment in the progress of European competition regulation. The UK passed its ‘DMCCA’ legislation and the EU began implementation of the Digital Markets Act (DMA.) Both adopt a new ex-ante approach (rules on behavior to prevent future harm.) However, as with so many industries, a potentially more important development took place on 4th November: Donald Trump was re-elected and is now back in the White House.
This briefing compares the regimes and includes reflections from DGA’s Washington DC team. The DMA has a proactive, rules-based approach entering the enforcement phase. The UK has a more flexible framework allowing the Competition and Markets Authority (CMA) to tailor interventions. It is also guided by the UK government’s requirement
for a focus on economic growth and industry engagement.