If you buy advertising that reaches people in Europe, European law has given you, since March 2024, a free daily record of what you actually paid for each individual advertisement, plus the data needed to have the inventory verified by a firm of your choosing.

Almost nobody claims it. Partly because the right is buried in three paragraphs of a regulation most coverage reduces to a story about browser choice screens on phones. Partly because it is scoped in a way that surprises people: the test is where the person who sees the advertisement is, not where you are. A company in Chicago running campaigns into Germany is inside the scope. The same company running campaigns in Ohio is not.

This article sets out what the regulation is, who it binds, what it grants you, and, more usefully, what each platform actually hands over when you go and look. Because the right exists, but its implementation carries limits that the platforms document themselves, in filings that are public and almost never read.

What the Digital Markets Act actually is

The text. Regulation (EU) 2022/1925 of the European Parliament and of the Council of 14 September 2022 on contestable and fair markets in the digital sector, published in the Official Journal of the European Union on 12 October 2022.

Its purpose, in its own words: to ensure “contestable and fair markets in the digital sector” for all undertakings. Put plainly, to stop a handful of very large platforms from locking up access to their users or quietly favouring themselves.

The date everyone cites is the wrong one. The regulation entered into force on 1 November 2022 and became applicable on 2 May 2023. Neither date is the one that matters. Article 3(10) gives designated undertakings six months to comply with articles 5, 6 and 7, which means the substantive obligations only became binding on 7 March 2024. The real track record is two and a half years, not four. The Commission makes this point itself.

And here is what separates it from every other digital statute: it binds seven companies. This is not a regulation of the internet. It is a regulation of seven named undertakings. For everyone else, including your business, the DMA creates no obligations at all. It creates claims.

That asymmetry is the single most useful thing to understand about it. Most regulation arrives as a cost. This one arrives, for a company your size, as a set of things you are entitled to ask for.

Who it binds, and why only three names matter to you

The seven undertakings designated as gatekeepers under the Digital Markets ActTable of the undertakings designated as gatekeepers under the European Union regulation on contestable and fair markets in the digital sector, together with the core platform services designated for each, as at the twenty third of September two thousand and twenty six. Seven undertakings are designated across twenty three core platform services. Alphabet is designated for Google Search, Google Play, Google Maps, Google Shopping, YouTube, the Android operating system, the Chrome browser and its online advertising service, since September two thousand and twenty three. Amazon is designated for its marketplace and its online advertising service, since September two thousand and twenty three. Apple is designated for the App Store, the iOS operating system and the Safari browser since September two thousand and twenty three, and for the iPadOS operating system since April two thousand and twenty four. Meta is designated for Facebook, Instagram, WhatsApp, Messenger and its online advertising service, since September two thousand and twenty three. Microsoft is designated for LinkedIn and the Windows operating system for personal computers, since September two thousand and twenty three. ByteDance is designated for TikTok since September two thousand and twenty three, and Booking is designated for Booking dot com as an online intermediation service since May two thousand and twenty four. The table records that for online advertising only three businesses are designated, those of Alphabet, Amazon and Meta, and that several advertising services were examined and then excluded, including those of X, TikTok and Microsoft, and Apple Ads and Apple Maps in February two thousand and twenty six, while Facebook Marketplace was removed from the list in April two thousand and twenty five after falling below the threshold of ten thousand business users.Seven undertakings, twenty-three servicesUndertakingDesignated servicesSinceAlphabetSearch, Play, Maps, Shopping, YouTube, Android,Chrome, and its advertising businessSept. 2023AmazonMarketplace, and its advertising businessSept. 2023AppleApp Store, iOS, Safari, then iPadOSSept. 2023MetaFacebook, Instagram, WhatsApp, Messenger, and its advertising businessSept. 2023MicrosoftLinkedIn, WindowsSept. 2023ByteDance, BookingTikTok, and Booking.com2023 and 2024Excluded after examination: the advertising businesses of X, TikTok and Microsoft, then Apple Ads in February 2026.
Seven undertakings, twenty-three services. For online advertising, only three businesses are designated. Source : European Commission (2026)

Note what that last line means. Several large advertising businesses argued that they were not an important enough gateway to be regulated, and won. So the advertising provisions of this regulation reach three companies: Alphabet, Amazon and Meta. If you buy media anywhere else, none of what follows applies to that spend.

Does any of this reach a US advertiser?

This is the question that decides whether the rest of the article is useful to you, and the answer is more favourable than most people assume.

The regulation sets no establishment test. Article 5(9) speaks of “each advertiser to which it supplies online advertising services”. There is no condition in the drafting about where that advertiser happens to be incorporated, and no recital introduces one.

What the platforms scope is delivery. Amazon states the rule about as plainly as it can be stated, in its public documentation: “The billable event (impression or click) must have been served to an EU country.” It then gives an example that settles the question entirely: “a Japanese advertiser who has campaigns in Japan can access the report, but it is expected that the report will not have any pricing data for the Japanese advertiser.”

Read what that example concedes. A company with no European presence whatsoever is not shut out of the report. It simply finds the report empty, because none of its advertisements reached anyone in the EU. Flip the facts and the conclusion flips with them: run campaigns that reach EU users, and the data is yours.

What determines whether the advertising disclosures of the Digital Markets Act cover a given campaignComparison of how the text of the European Union regulation on contestable and fair markets in the digital sector and the designated advertising businesses describe what determines coverage of the advertising disclosure obligations, and what that means for an advertiser established outside the European Union. The regulation itself sets no establishment test: paragraph nine of article five refers to each advertiser to which the gatekeeper supplies online advertising services, with no condition as to where that advertiser is established. Amazon states in its public documentation that the billable event, meaning an impression or a click, must have been served to a European Union country, and offers the example of a Japanese advertiser running campaigns in Japan, who can access the report but should expect it to contain no pricing data, because none of that advertiser advertisements reached users in the European Union. Alphabet documentation states that no report is generated for an account that has no traffic served to end users in the European Economic Area on a given day. Meta describes its dedicated pricing report as covering advertisements delivered to people in the European Economic Area. The figure concludes that every operative test concerns where the advertisement was delivered rather than where the advertiser is incorporated, so that an advertiser established in the United States holds these rights over the share of its spending that reaches European users, and holds no equivalent right over the campaigns it runs domestically.Delivery is the test, not incorporationThe regulation“Each advertiser to which it supplies online advertising services.” No establishment test anywhere in the drafting.Amazon, in its public documentation“The billable event must have been served to an EU country.” And a Japanese advertiser running Japanesecampaigns “can access the report”, it simply comes back empty.Alphabet and Meta, same logicNo report where an account has no traffic served to EEA end users. And “ads delivered to people in the EEA”.So a US advertiser holds this right over its European spend, and over nothing elseCampaigns served entirely to users outside the EEA fall outside. No reading of this regulation covers your domestic spend.
Every test is about where the advertisement landed. None of them is about where the advertiser is incorporated. Source : Amazon Ads documentation and platform compliance reports (2026)

Alphabet and Meta scope it the same way. Alphabet’s documentation states that no report is generated where an account has no traffic served to EEA end users on a given day, and Meta describes its dedicated pricing report as covering “ads delivered to people in the EEA”. One wrinkle worth flagging for completeness: Alphabet’s compliance report describes the consent it seeks from publishers as consent to share price data “with EEA advertisers”, which sits a little awkwardly beside its own access rule, under which recipients “must be Google’s advertiser customers, or third parties acting on their behalf” with no geographic qualifier attached.

So the practical position is this. If you are a US company with any European campaign activity, however modest, you hold a data right over that portion of your spending that you hold over no other part of it. Most advertisers in that position have never exercised it, and many have never been told it exists.

And the converse is just as firm. Campaigns served entirely to users outside the European Economic Area are outside the scope. Nothing in this regulation gives you a data right over your domestic US spend. If that strikes you as the more consequential gap, the section below on what the United States offers instead is the one to read.

The part nobody explains: three provisions written for advertisers

Three paragraphs create rights that are enforceable against the designated advertising businesses. They are exercisable on request, free of charge, and the text expressly extends them to third parties authorised by the advertiser, which is what makes an external audit legally possible.

The three advertising provisions of the Digital Markets ActPresentation of the three provisions of the European Union regulation on contestable and fair markets in the digital sector that create rights an advertiser can exercise directly against a designated advertising business. The first, paragraph nine of article five, requires the gatekeeper to provide each advertiser, or third parties authorised by advertisers, upon request and on a daily basis free of charge, with information concerning each advertisement placed, covering the price and fees paid including any deductions and surcharges, the remuneration received by the publisher subject to that publisher consent, and the metrics on which each of the prices, fees and remunerations are calculated. The second, paragraph ten of the same article, is the mirror provision for publishers, who receive on the same daily and free basis the remuneration they receive for each advertisement displayed in their inventory together with the price paid by the advertiser, subject to the advertiser consent. The third, paragraph eight of article six, requires the gatekeeper to provide advertisers and publishers, and third parties authorised by them, upon request and free of charge, with access to the performance measuring tools of the gatekeeper and to the aggregated and non aggregated data necessary for them to carry out their own independent verification of the advertisements inventory, such data to be provided in a manner that enables them to run their own verification and measurement tools. The figure records that all three rights are exercisable on request, are free of charge, are transferable to an authorised third party, and bind only the three designated advertising businesses, those of Alphabet, Amazon and Meta.Three articles, three claimsArticle 5 (9)What you actually paid, daily, advertisement by advertisementPrice and fees paid, deductions and surcharges included. The remuneration the publisher received,subject to consent. And the metrics on which all of it is calculated.Article 5 (10)The same thing, mirrored, for the publisherWhat it earns on each impression, and what the advertiser paid, if the advertiser consents.Article 6 (8)Enough to have the inventory verified by someone elseFree access to the platform’s measuring tools, and to the aggregated and non-aggregated dataneeded for your own independent verification of the advertisements inventory.Free, on request, transferable to a third party you authorise. Binding on the advertising businesses of Alphabet, Amazon and Meta.
Three articles, three enforceable claims against the advertising businesses of Alphabet, Amazon and Meta. Source : Regulation (EU) 2022/1925 (2026)

What the text actually says

It is worth reading, because the drafting is sharper than the summaries of it.

Article 5(9) requires the gatekeeper to supply each advertiser, “or third parties authorised by advertisers, upon the advertiser’s request, with information on a daily basis free of charge, concerning each advertisement placed by the advertiser”. Three items specifically: the price and fees paid, deductions and surcharges included; the remuneration received by the publisher, subject to that publisher’s consent; and “the metrics on which each of the prices, fees and remunerations are calculated”.

Article 6(8) goes further, and it is the one to remember. The gatekeeper must give advertisers and publishers, “as well as third parties authorised by advertisers and publishers, upon their request and free of charge, with access to the performance measuring tools of the gatekeeper and the data necessary for advertisers and publishers to carry out their own independent verification of the advertisements inventory, including aggregated and non-aggregated data”. The text adds that the data must be provided “in a manner that enables advertisers and publishers to run their own verification and measurement tools”.

Your tools. Your vendor. Your queries. Not the platform’s dashboard.

What happens when the other side says no

Here is the detail commentary almost universally drops, and it changes the calculation.

The publisher’s remuneration is disclosed to you only “subject to the publisher’s consent”. You would reasonably assume a refusal guts the right. It does not. The very next subparagraph provides that where a publisher withholds consent, “the gatekeeper shall provide each advertiser free of charge with information concerning the daily average remuneration received by that publisher, including any deductions and surcharges, for the relevant advertisements”.

A refusal costs you granularity, not the information. You drop from a figure per advertisement to a daily average per publisher. That is worse, but it is a long way from nothing, and it is still more than any advertiser had before 2024. The mirror provision protects publishers when it is the advertiser who refuses.

What each platform actually hands over

The right is identical for all three. The implementation is not remotely identical. We went and read the compliance reports these companies file with the Commission and publish themselves, because that is where the operative limits are written down, not in their help centres.

What the three designated advertising businesses actually supply under the advertising obligations of the Digital Markets ActTable comparing what the three advertising businesses designated as gatekeepers under the European Union regulation on contestable and fair markets in the digital sector actually supply to advertisers and publishers, drawn from the compliance reports those undertakings file and publish themselves. On the daily report required by paragraphs nine and ten of article five, Alphabet supplies a downloadable daily file, separate for each advertising product; Amazon supplies a pricing transparency report through its advertising console and its publisher portal; Meta supplies information built into its existing tools together with an additional dedicated pricing report that covers only advertisements shown on third party mobile applications. On the independent verification required by paragraph eight of article six, Alphabet offers publishers a non aggregated data solution and has extended click level reporting for advertisers; Amazon has introduced a secure environment in which advertisers run their own queries to verify campaign performance independently; Meta relies on its existing tools and programming interfaces with no dedicated environment. All three are self service. Consent by the counterparty to sharing pricing information is a single global yes or no at all three, with no ability to vary it. Coverage is confined to the European Economic Area at all three, which is the point that determines whether an advertiser outside Europe is in scope. Finally, on the limits these undertakings document themselves, Alphabet states that the event identifier contained in its files does not function as a join key with the campaign identifier or with any other event level data it provides; Amazon publishes neither a retention depth nor a delivery delay; and Meta confines its dedicated report to third party application inventory.What each one actually gives youDrawn from the compliance reports these companies file with the Commission themselves.What we looked atAlphabetAmazonMetaThe daily reportarticles 5 (9) and 5 (10)Downloadable daily file,one per productPricing transparencyreportDedicated report, third-partyinventory onlyThe verificationarticle 6 (8)Non-aggregated data,click-level reportingSecure environment,you write the queriesExisting tools and APIs,no dedicated environmentHow you get itSelf-service, switch it onSelf-serviceSelf-serviceConsent to shareOne global yes or noSame, off by defaultSameCoverageEuropean Economic AreaSameSameThe limit they documentthemselvesNo join key back tothe campaignNeither depth nor delaypublishedScope limited tothird-party inventoryNo common standard requires a shared format. Each business discloses what it chooses, in the shape it chooses.
Three different mechanisms, no common format, and therefore nothing you can compare across them. Which is precisely what the Commission records. Source : DMA compliance reports of Alphabet, Amazon and Meta (2026)

Alphabet. The obligation takes the form of a daily downloadable file, separate for each advertising product, on the advertiser side and the publisher side alike. For every billable advertisement it carries an event identifier, the amount you paid, and the amount bid into the auction. Switching it on is self-service, inside the product’s settings. For article 6(8), Alphabet offers publishers a non-aggregated data solution and has extended the availability of free click-level reporting to advertisers. Worth noting: its most capable analysis environment predates the regulation, is not presented as the compliance answer, and sits behind a spend threshold.

Amazon. The clearest of the three, and the only one with dedicated public documentation. A pricing transparency report sits in the advertising console and in the publisher portal. More to the point, Amazon states in its compliance report that it has introduced “a new clean room environment where Advertisers can independently verify the performance of their ad campaigns”. That is the most literal reading of article 6(8) of the three. Sharing data with the counterparty is, however, off by default.

Meta. This is where reading the filing changes the conclusion you would have drawn from the marketing pages. Meta explains that it complies with article 5(9) in two ways: through the tools it already offered advertisers, and “by maintaining an additional pricing report in respect of ads shown on third-party applications via Audience Network”.

Read that again. The report built specifically for this regulation covers third-party app inventory only. For your campaigns in the Facebook feed, on Instagram, in Reels, which is to say for most of what an advertiser spends with Meta, the company’s position is that its pre-existing tooling already satisfies the obligation.

The position is not unreasonable. Articles 5(9) and 5(10) are drafted for an intermediation scenario: they speak of the price paid by the advertiser and the remuneration received by the publisher. Where Meta sells inventory on its own surfaces there is no third-party publisher, and half the obligation has nothing to describe. But the practical result stands: across the bulk of your Meta budget, this regulation has given you nothing you did not already have.

Three limits that keep this from changing the game

A right of access is only worth what you can do with the data. Three obstacles, each documented either by the platforms or by the Commission, explain why these obligations have not yet reshuffled anything.

The first is technical, and it is the most severe. Alphabet’s compliance report states, of the files produced under articles 5(9) and 5(10), that they contain “an Event ID, which does not function as a join key with Campaign ID (available in other reporting provided by Google) or any other event-level data provided by Google”. The stated justification is commercial confidentiality, end-user privacy and invalid-traffic protection.

Translated: you receive the exact price of every advertisement, and you cannot determine which campaign it belonged to. You hold the truth at the event level and the truth at the campaign level, and you are structurally prevented from putting them side by side. That is the heaviest constraint in the entire mechanism, and it is deliberate.

The second is scope, which we have just seen at Meta.

The third is the binary consent. The Commission puts it flatly in its April 2026 staff working document: “currently gatekeepers only allow a global consent (yes or no) for a party to share or not share pricing information with counterparties”. You cannot consent for one counterparty and not another, for one campaign and not another.

That same document is, for the rest, remarkably even-handed, and deserves quoting in both directions. On one side, the Commission judges that these developments “represent a clear step beyond the pre-DMA baseline”. On the other, it records that business users report “persistent issues in obtaining sufficiently granular and comparable data”, and adds a sentence worth dwelling on: those businesses “often mentioned gatekeepers’ arguments around privacy to justify withholding sufficiently granular data which, according to these stakeholders, can perpetuate information asymmetries”.

Its list of unresolved problems is specific: “insufficient granularity for comparability, lack of standardisation across platforms, inflated campaign metrics, geographical limitations on reporting, and restricted access to raw or log-level data”. Some member states pressed for an interoperability obligation on advertising tools. The Commission’s own conclusion is cautious: “it is also therefore too early to fully assess whether it is necessary to consider amending the provisions or their scope”.

What that means for you. You hold a real, exercisable right of access that did not exist before March 2024. You can audit one advertising business. You cannot yet put two of them side by side on the evidence. That is still a great deal more than most advertisers ever ask for.

How to actually exercise it

How to exercise the advertising data rights conferred by the Digital Markets Act, in five stepsFive step procedure for an advertiser to exercise, in practice, the advertising data rights conferred by paragraphs nine and ten of article five and paragraph eight of article six of the European Union regulation on contestable and fair markets in the digital sector. Step one, switch the disclosure on inside the platform interface: none of these reports is active by default, each is enabled in the settings of the advertising product concerned, and no formal request, accreditation or spending threshold is involved. Step two, automate the daily collection: the files are produced each day and platform retention is limited, so collecting them by hand loses the history, and it is the history rather than any single day that carries the analytical value. Step three, formally authorise the verification vendor: the text expressly extends these rights to third parties authorised by the advertiser, which is the only legal basis for an external audit and requires an explicit authorisation inside the interface. Step four, reconcile the data against your own measurement, which is the stage at which the documented limits become visible, in particular the inability to join the event identifier supplied by Alphabet back to the campaign identifier. Step five, where access is refused or the data proves insufficient, report it: article twenty seven allows any third party, including business users and competitors, to inform either the competent national authority or the European Commission directly, subject to the qualification that the Commission retains full discretion over what it does with such information.Claiming it, in five steps1Switch the disclosure onNothing is on by default. No formal request, no accreditation, no spend threshold. A setting to enable.2Automate the daily collectionFiles are daily and retention is short. Collecting by hand means losing the history that carries the value.3Formally authorise your verification vendorThe text names third parties authorised by the advertiser. This is the legal basis for any external audit.4Reconcile against your own measurementThis is where the limits surface, starting with the missing join key back to the campaign.5If refused, report itArticle 27 opens a route to the national authority or the Commission. With no guarantee of follow-up.
The two steps everyone skips: automating collection, and formally authorising the verification vendor.

Step five deserves its caveat. Article 27 allows any third party, “including business users, competitors or end users”, to inform the competent national authority or the Commission directly. But the same article states that the Commission retains full discretion over what it does with that information. A report does not create a right to a decision, unlike a formal complaint in antitrust practice. It is nonetheless the route the regulation provides, and the preliminary findings issued since 2024 show these reports do feed the pipeline.

The other provision worth knowing about

If your business depends on a designated platform rather than merely advertising on it, article 6(9) is the one to read. GDPR has granted a right to data portability since 2018, but without any obligation to provide tooling or continuity: you can request an export and then work out what to do with it.

The DMA adds the part that was missing. The gatekeeper must provide effective portability “including by providing, free of charge, tools to facilitate the effective exercise of such data portability, and including by the provision of continuous and real-time access to such data”. Article 6(10) extends equivalent continuous, real-time access to business users for the data their own activity generates on the platform.

That is the difference between being handed an archive and being given a feed. The Commission reports that more than forty companies, mostly small and medium enterprises, have built services on this basis. Modest against the ambition of the text, but it is a category of business that did not previously exist.

Breach of any of this is expensive in principle: up to 10 per cent of worldwide turnover, rising to 20 per cent for a repeat breach, which the regulation defines narrowly as the same or a similar infringement, on the same core platform service, within eight years of an earlier finding. Three non-compliance decisions have issued so far, totalling 1.59 billion euros, and none of them has approached the statutory ceiling.

What the United States offers instead

Nothing comparable, and the reason is structural rather than accidental. Europe legislated an obligation in advance. The United States litigates conduct after the fact. Both approaches are defensible. They produce very different things for an advertiser.

How the European Union and the United States each address the same opacity in advertising marketsComparison of the European and United States approaches to the same problem of opacity in programmatic advertising markets. The European Union proceeds by standing obligation imposed in advance: the regulation on contestable and fair markets in the digital sector was adopted in September two thousand and twenty two, its substantive obligations became binding in March two thousand and twenty four, and it applies to seven designated undertakings regardless of any finding of wrongdoing, giving advertisers a right of access exercisable directly against the platform without going to court. The United States proceeds by litigation after the fact: in the Justice Department advertising technology case before the Eastern District of Virginia, Judge Leonie Brinkema found in April two thousand and twenty five that Google had unlawfully monopolised the publisher advertising server market and the advertising exchange market and had unlawfully tied the two, while rejecting the claim concerning advertiser advertising networks for want of a proven relevant market. The remedies opinion of one hundred and six pages, issued on the second of September two thousand and twenty six and unsealed on the sixteenth, declined to order divestiture of the advertising exchange and imposed behavioural remedies instead, including sharing real time bid data with rival advertising servers and the prohibition of first look and last look bidding privileges. The figure records the two consequences that matter to an advertiser: the European route delivers a standing right that does not depend on proving anything, while the United States route delivered remedies addressed principally to publishers, after more than three years of proceedings, and with a final judgment still outstanding.Two ways of attacking the same opacityEurope: obligation, in advanceAdopted September 2022. Binding fromMarch 2024.Applies to seven undertakings whether ornot anyone has done anything wrong.The advertiser claims it directly. No court,no proof of harm, no standing to establish.United States: litigation, afterwardsFiled 2023. Liability found April 2025 onthe publisher ad server and exchange.The advertiser-side market claim failed forwant of a proven relevant market.Remedies September 2026. Divestiturerefused. Behavioural fixes instead.And here is the asymmetry that matters if you buy mediaThe European route hands you a file. The American route handed publishers a set of rules, after three years, on appeal.Everything the US industry offers on transparency, from measurement accreditation to supply-chain specifications, is voluntary.A platform may adopt it. Nothing compels it to, and no fine follows if it does not.Bills that would change this have been introduced repeatedly since 2022 and none has passed.
One produced a daily file in March 2024. The other produced a remedies opinion in September 2026, and it was about publishers.

The litigation route, briefly. In the Justice Department’s advertising technology case in the Eastern District of Virginia, Judge Leonie Brinkema found in April 2025 that Google had unlawfully monopolised the publisher ad server market and the ad exchange market, and had unlawfully tied the two. Notably for advertisers, the claim concerning advertiser ad networks failed, because the court was not persuaded that a distinct relevant market had been established.

The remedies opinion, 106 pages, issued on 2 September 2026 and unsealed on the 16th, declined to order divestiture of the exchange and imposed behavioural remedies instead: sharing real-time bid data with rival ad servers, and an end to first-look and last-look bidding privileges, among others. A final judgment had not been entered at the time of writing, and an appeal is expected.

Set the two timelines side by side. European advertisers have had a daily price file since March 2024. The American case, filed in 2023, produced a remedies opinion in September 2026 that is principally about publishers and is not yet final.

And the voluntary layer is exactly that. Measurement accreditation, supply-chain specifications such as the seller and supply-chain disclosure files, certification seals: all of it is industry self-regulation. A platform may adopt it. Nothing obliges it to, and no penalty attaches to declining. That is the whole distinction this article turns on. The DMA provisions are obligations, breach of which exposes a company to a fine of up to 10 per cent of worldwide turnover.

Bills that would change the US position have been introduced repeatedly since 2022, covering platform self-preferencing, app store conduct and cross-ownership of advertising exchanges. At the time of writing none has passed, and the relevant ones remain in committee.

Why it matters even if you never run a European campaign. The industry’s own numbers explain the appetite. The ANA’s Programmatic Media Supply Chain Transparency Study of December 2023, built on the log-level data of 21 advertisers across 123 million dollars of spend and 35.5 billion impressions, concluded that only 36 cents of every dollar entering a demand-side platform effectively reaches the consumer. In the United Kingdom, ISBA and PwC measured an “unknown delta”, spend that simply could not be traced anywhere in the chain, of 15 per cent in 2020, narrowed to 3 per cent by their January 2023 follow-up. Those are the conditions the European provisions were written against.

Who else is copying this

Jurisdictions that have adopted or are considering legislation modelled on the Digital Markets ActTable of jurisdictions outside the European Union that have adopted or are considering legislation modelled on the European regulation on contestable and fair markets in the digital sector, with the status of each as at the twenty third of September two thousand and twenty six. In the United Kingdom, the Digital Markets, Competition and Consumers Act of two thousand and twenty four is in force and the Competition and Markets Authority designated Google with strategic market status for general search and search advertising in October two thousand and twenty five, and designated Apple and Google for their mobile platforms in the same month, imposing three conduct requirements to date covering content attribution, fair ranking and data portability. In Japan, the act on promotion of competition for specified smartphone software entered into force in December two thousand and twenty five, with Apple and Google designated in March two thousand and twenty five and compliance reports published in February two thousand and twenty six. In South Korea, Brazil, India and Australia, only bills or announced intentions exist, none of which has been enacted. The table records the point that matters for advertising specifically: even in the United Kingdom, which operates the regime closest to the European one, the competition authority has placed greater transparency of search advertising in a category for future consideration and has deprioritised measures concerning advertising auctions and prices, so that no obligation equivalent to paragraphs nine and ten of article five or paragraph eight of article six has yet been imposed outside the European Union.Where else this is happeningJurisdictionInstrumentStatusUnited KingdomDigital Markets, Competition andConsumers Act 2024In force. Google and Appledesignated October 2025JapanAct on competition for specifiedsmartphone softwareIn force December 2025.Apple and Google designatedSouth Korea, BrazilPlatform fairness billsBills only, not enactedIndia, AustraliaDigital competition proposalsStudy stage, nothing in forceBut nobody has copied the advertising transparency partEven the UK regulator has placed search advertising transparency in a “future consideration” bucket and deprioritisedmeasures on advertising auctions and prices. The obligations in this article exist in one jurisdiction on earth.
Two regimes are actually in force with designated companies. The rest are bills.

That last point is the one to take away. Two jurisdictions outside the EU have a comparable regime actually in force, the United Kingdom and Japan, and neither has replicated the advertising disclosure obligations. The UK regulator designated Google in October 2025 for search and search advertising, then imposed conduct requirements on content attribution, fair ranking and data portability. Greater transparency of search advertising sits in its “future consideration” category, and measures on advertising auctions and prices have been deprioritised outright.

So the right described in this article currently exists in exactly one place.

Where to get the text, and the documents that are actually useful

The regulation runs to 66 pages in the Official Journal and reads better than you would fear. Articles 5, 6 and 7 carry almost all of the obligations, and the recitals that precede them explain the reasoning.

The text. The consolidated version folds in the two corrigenda published since 2022 and updates itself if the regulation ever changes, which it has not done on substance.

The documents that tell you what is actually happening. These are less well known and far more useful day to day: the Commission’s own assessment, and what each platform states it provides.

We link to the official sites rather than hosting copies. A frozen PDF on someone else’s server goes stale without telling you.

What to do with this

Four things, in order of how easy they are.

Switch the disclosures on this week, if you run any European campaigns. The files required by articles 5(9) and 6(8) exist, are free, and are enabled in self-service. Nothing is on by default and nobody is going to suggest it to you. Once enabled, automate the collection: the files are daily and retention is short, so waiting six months before taking an interest means having lost six months of data.

Know in advance what you will not get. With Alphabet you will not be able to tie an advertisement’s price back to its campaign. With Meta the report built for this regulation does not cover your feed or Instagram campaigns. Going in with that knowledge is the difference between a useful exercise and a wasted quarter.

If you spend enough for it to pay, have the inventory verified by a third party. Article 6(8) expressly names third parties authorised by the advertiser. That is the legal basis for an independent audit, and it was close to impossible before 2024. The authorisation is granted inside the interface, and it is the step almost everyone forgets.

If your business depends on a platform rather than merely advertising on it, read articles 6(9) and 6(10). You have a right to export your data continuously and in real time, and to reach the data your own activity generates there. That is what turns switching platforms from a theoretical option into a practical one.

The Digital Markets Act was not written with small and medium businesses in mind, and it asks nothing of them. But it handed them claims that no other body of law provides, on one condition: that somebody asks.

Related reading: Media buying explained and Why CPM varies so much.