The EU’s Digital Markets Act (DMA), passed in September 2022, contains a range of measures to improve fairness and competition in the digital sector. It requires the very largest technology companies (“gatekeepers”), such as Apple, to meet obligations in relation to their “core platform services”, such as the iPhone operating system iOS. These include enabling third-party hardware and service providers to use all the features of an operating system (OS) which are available to a gatekeeper’s own hardware or services (Article 6(7) DMA). This is often referred to as “vertical interoperability”.

As the main DMA enforcer, the European Commission (EC) has taken a comprehensive approach to addressing iOS interoperability with connected hardware, from payment cards and virtual reality headsets to smart homes and cars. It opened an investigation into Apple’s compliance in September 2024, publishing preliminary findings in December 2024 for public consultation, and specifying a range of proposed measures Apple should take.

In my assessment, the EC’s proposed measures are narrowly and carefully drawn to enable Apple to comply with the DMA 6(7) obligation and so provide fair and non-discriminatory iOS treatment of third-party connected devices. They are a good example of how careful, case-by-case analysis can maintain the security, privacy and integrity of a DMA-designated operating system (OS) or virtual assistant while opening related markets up to fair competition.