What is the Digital Marketing Act?

Before we answer how the DMA will affect SEO let's first take a look at what these regulations target and the associated obligations.

In September 2023 the European Commission announced Regulation (EU) 2022/1925 also known as the Digital Markets Act (DMA) would include Google as a “Gatekeeper”. We’ll discuss what that means and some of the implications in the following text.

By targeting the largest digital platforms operating within the European Union the legislation aims to prevent these companies from abusing their market power, ensuring they are not able to monopolise a market or unfairly promote their own products. These companies are also referred to as “Gatekeepers”.

Three primary criteria determine if it falls under the scope of the DMA:

  • Size affecting the internal market: The company must achieve a certain annual turnover within the European Economic Area (EEA) and offer a core platform service in at least three EU Member States.
  • Control of a significant gateway for business users to reach final consumers: The company must provide a core platform service to over 45 million monthly active end users in the EU and to more than 10,000 yearly active business users in the EU.
  • Established and enduring dominance: The company must have met the second criterion consistently over the past three years.

Failure to comply may result in fines of up to 10% of global turnover.

The DMA's main goal is to create a fair competitive environment within the highly concentrated digital markets of Europe, often dominated by a few key players - a key one being online search engines such as Google.

It targets eight sectors known as Core Platform Services (CPS), including online search engines, online intermediation services, social networks, video-sharing platforms, communication platforms, advertising services, operating systems, and cloud services. These sectors are considered problematic due to the presence of gatekeepers that impact market contestability.

There are twenty-two services operated by six companies which are deemed “Gatekeepers” with Alphabet, Amazon, Apple, ByteDance, Meta and Microsoft being identified as core platform services.

These companies will have until 6th March 2024 to comply with all the Digital Marketing Act provisions and associated obligations.

These obligations include prohibiting the merging of data collected from different services owned by the same company, safeguarding the interests of business users on platforms, preventing self-preferencing practices, addressing pre-installation of services, bundling practices, and ensuring interoperability and data access. 


Is the Digital Marketing Act (DMA) just about Europe?

Within the UK the DMA has influenced similar legislation with the Digital Markets, Competition and Consumers Bill as an amendment to the Competition Act of 1998. At the time of writing, this is currently being debated and reviewed by Parliament.

Within the United States, there is no official position yet, however, the DMA directly affects American Big Tech firms and has synergy with some of the debates rising in the USA about digital tech platforms and their dominant positions.


So Why Is the DMA Needed?

In 2006 Froogle which later became Google Shopping was investigated and penalised by the European Union due to anti-trust violations.

The EU determined that Google consistently ranked its own comparison shopping service at the top of search results, giving it preferential treatment over competitors. This practice ensured higher visibility and exposure for Google Shopping, effectively providing a disadvantage to other comparison shopping services. Additionally, Google was found to systematically demote competing comparison shopping services in its search results. This deliberate suppression of competitors' visibility further solidified Google's dominance in the market and hindered fair competition.

It's not just Google that has a history of being penalised by the EU for overly promoting their own services - Meta and Amazon have also been subject to similar regulations in recent years.
As you can see from the examples above the EU has a history of finding and prosecuting anti-trust violations within the big tech companies. While the companies listed as gatekeepers hold significant monopolies these companies the monopolies themselves are not the issue. The reason for the DMA is therefore to reduce anti-trust violations. These violations effectively prevent competitors from competing in the marketplaces owned by the Gatekeepers.


How Does the Digital Marketing Act Affect SEO

During this article thus far we’ve discovered that the purpose of the Digital Marketing Act is to remove anti-trust violations in the SERPS. This means providing more visibility to third-party pages. 

In order to promote these third-party pages it stands to reason that other websites will lose out in the SERPS. 

We are already seeing some changes in the Google landscape being tested and rolled out, with some examples later on in this article.


How Does the Digital Marketing Act Affect Hotel SEO

Big internet companies, like online travel agencies (OTAs) in the hotel industry, must follow rules set by the European Union (EU) or risk significant fines. These rules aim to reduce the dominance of these large companies and provide advantages to both European businesses and internet users. According to HOTREC, the top three players in the OTA market are Booking Holding, Expedia Group, and HRS Group, which together hold 92% of the market share.



The obligations and prohibitions placed on gatekeepers could yield several advantages for your hotel:

  • Platforms will be compelled to enhance transparency in how they rank and present accommodation options to users. This means hotels will gain access to data on how their name, content, and Average Rate Index feed (ARI Feed) are utilised by Online Travel Agencies (OTAs). Additionally, OTAs will be required to provide more comprehensive data on your advertisements, including performance metrics on metasearch and paid search.
  • Regulations will limit how platforms can exploit data collected through their services.
  • Hotels will enjoy the ability to seamlessly transfer their listings and customer information from one platform to another.
  • Practices such as imposing price parity clauses on hotels will be forbidden.
  • Platforms will be mandated to allow other travel service providers to access their platforms, enabling them to offer complementary services.

While currently none of the OTAs have been designated as a gatekeeper, the introduction of the DMA regulations signifies an impending transformation in the dynamics of hotel-OTA partnerships,

For hotels specifically the search landscape is changing considerably. The main changes include bubbles which appear after the user searches for a particular keyword including hotels. These bubbles include several new options such as prices, dates and reviews

Prior to the update, Google Hotel Finder (Hotel SERP Pack) could often be found directly in the SERPs as the leading result and included many pay-to-play pricing within the SERP feature. One of the significant changes is that it now displays the hotel price only with users needing to click through to see advertisers 

Example of Google Hotel Finder

Previously when clicking the hotel in the SERP result this took you directly to Google Hotels





However, the updated search results open these secondary results in a side panel rather than navigating to Google’s Hotel Platform

Search Engine Roundtable also released the following video in their recent post here indicating further changes being noted by some users to the SERPs. The new modules highlighted give more visibility to third parties as well as additional features like the comparison sites carousel.



With these changes to the SERPs the SEO landscape is likely to become more open to competition, with comparison sites and OTAs in the short to medium term gaining new positioning.

Affected niches should therefore look to spread their own marketing spend in the short to medium term.

However, the DMA is also scheduled for further revision and review in 2025 and there are strong reasons to believe that larger players in some niches will also be denoted as “Gatekeepers”. Within these niches, it is therefore sensible to look at the specific marketing elements of individual websites with a view to gathering your own data and marketing expertise should the market experience further shift.

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Carl spends his days helping our clients elevate their brands through the power of SEO. From creating strategies designed to deliver excellence and meet objectives, to implementing campaigns that deliver next-level results, Carl loves it all. 

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