The Brussels Effect in Action: Apple Adjusts to Europe’s Digital Markets Act

In April 2025, the European Union imposed fines of 500 million euros on Apple Inc. and 200 million euros on Meta, based on indications that both companies had violated the European Union’s Digital Markets Act (DMA) regulations. Apple was accused of violating the anti-steering obligation regulated in the DMA. It was found that Apple had imposed several restrictions on developers, preventing them from benefiting more from the availability of alternative payment methods outside of Apple.

The fine imposed by the European Union is valid because Apple acts as one of the DMA gatekeepers that has agreed to comply with all regulations set in March 2024. Since Apple has complied with the DMA, Apple’s rules, which were previously very exclusive and did not allow competitors to enter its platform, are now more inclusive. Apple’s more inclusive regulations in the European Union have then come under pressure from several other developed countries to be implemented globally. To that end, this essay aims to understand the reasons why Apple complies with the DMA to the extent of changing some of its regulations in the European Union, which could certainly trigger other countries to pressure them to change globally, a phenomenon that reflects the Brussels Effect by the European Union.

Market Power Europe

The strength of a country’s internal market is closely related to the global economy. Producers will tend to follow the standards of important markets to secure access there. The European Union is the largest single market with a gross domestic product (GDP) of nearly USD 16 trillion, consisting of a single market with 500 million consumers (Bradford, 2012). This is reinforced by the fact that the European Union, which has only 7% of the world’s population, generates nearly 22% of the world’s wealth, which is greater than the United States, China, and India (Van Rompuy, 2010, in Damro, 2012). The European Union has the largest consumer market with many wealthy consumers, prompting many producers to maximize their ability to supply the EU market. The profits gained from the large number of wealthy consumers in the European Union make companies more interested in entering the market because the profits can cover the necessary adjustment costs. These companies rationally choose to take advantage of market access because if they do not enter the European Union market, they potentially lose huge profits that cannot be obtained from their home countries or developing countries.

Apple Inc. Affected by the Brussels Effect

The DMA is a derivative rule of the normative power held by the European Union. The DMA reflects the value of fair competition, requiring many gatekeepers to open up more opportunities for other developers to enter their platforms. Apple in the European Union is included in the gatekeeper criteria set by the DMA. Although Apple has not yet implemented the DMA on a massive scale globally, Apple’s move to comply with the DMA as one of its own gatekeepers already reflects the Brussels effect brought about by the European Union. Without military power as great as that of the US or rapid economic growth like China, the European Union can have global regulatory power through the Brussels Effect. In the context of its analysis of Apple Inc. complying with the DMA, the Brussels Effect can occur because the EU market is important for global companies, so they will choose to follow EU standards rather than create many different versions of products for each market. One example is that payments through Apple using third parties did indeed originate from the implementation of the DMA in the EU, but this is also already partially applicable in South Korea. This phenomenon has become a driving force for Apple to implement the same regulations as those already applied to its compliance with the DMA.

Another thing about Apple’s default app settings, like email and browsers, where Apple already provides options from other developers, is an example of how Apple’s inclusive regulations can actually be implemented by Apple. The DMA will encourage Apple to apply its regulations globally, seeing how other developed countries with large markets are also starting to implement rules similar to the DMA. Examples include Australia with the Australian Competition and Consumer Commission, South Korea with its antitrust regulations, and India with the Competition Commission of India (CCI). This also reflects the de jure Brussels Effect, where other countries adopt European Union regulations.

Apple Inc. is often known as a company with exclusive products. This is not only because its products are relatively expensive but also because Apple’s own regulations do not open up opportunities for developers outside the company to enter its platform. Now, Apple has begun to open up opportunities for other developers to enter their platform, especially in the European Union. Quoted from Apple’s developer website, some examples of Apple’s changing regulations include adding additional options for developers to distribute applications on iOS and iPadOS, process payments, and use web browsers on iOS and iPadOS. This is an implication of Apple’s compliance with several rules listed in the DMA, such as allowing their business users to access the data they generate when using the gatekeeper platform, prohibiting consumers from connecting to businesses outside their platform, and allowing third parties to collaborate with gatekeeper services in specific situations.

In fact, Apple has the option of not complying with the DMA and withdrawing its products from the European Union market, but Apple has chosen to comply with the DMA. This is one of the effects of European market power, where the European Union accounts for nearly 22% of the world’s wealth, with the largest consumer market that has many wealthy consumers. This implies that more and more manufacturers are trying to maximize their ability to supply the European Union market. Based on European market power, the profits gained from the large number of wealthy consumers in the European Union make companies more interested in entering the market because the profits can cover the necessary adjustment costs. These companies rationally choose to take advantage of market access because if they do not enter the European Union market, they could potentially lose huge profits that cannot be obtained from their home countries or developing countries. For this reason, Apple has also chosen to comply with the DMA rather than withdraw its products from the European Union. This is reinforced by data comparing Apple’s total global profits with its profits in Europe. Apple earned USD 97 billion in global profits and USD 28 billion in Europe, equivalent to 29% of Apple’s total global profits. Therefore, if Apple withdrew its products from the European Union, it would certainly lose this huge market and profits.