Apple Ads and Apple Maps Face EU ‘Gatekeeper’ Test Under Digital Markets Act as Apple Files Rebuttals

Brussels, 28 November 2025 – Apple has formally told the European Commission that two of its key services, Apple Ads and Apple Maps, cross the size thresholds of the EU Digital Markets Act (DMA), triggering a fresh review that could see them designated as “gatekeepers” and subjected to tough competition rules. At the same time, the company has submitted official rebuttals arguing that neither service should be covered by the law’s strictest obligations. ^[1]

The move deepens an already tense stand‑off between Apple and Brussels over how much control large technology platforms should have over digital markets and user data in the European Union.

What Happened on 28 November 2025

On Friday, EU competition regulators confirmed they will examine whether Apple Ads and Apple Maps qualify as gatekeepers under the DMA after Apple notified them that both services meet the law’s size criteria. ^[2]

According to the Commission:

Apple’s notification arrived on 27 November 2025 and covered Apple Ads and Apple Maps as “core platform services”.
The Commission now has 45 working days to decide whether these services will be formally designated as DMA gatekeepers.
If designated, Apple would have six months to bring each service into full compliance with the law. ^[3]

In parallel, Apple confirmed it has submitted rebuttals to pre‑designation notices issued by the Commission. In those filings, the company argues that Apple Ads is a relatively small advertising player in the EU and that Apple Maps lacks the kind of marketplace role that would justify a gatekeeper label. ^[4]

What Is the Digital Markets Act and What Is a Gatekeeper?

The Digital Markets Act is the EU’s flagship law to rein in dominant digital platforms that act as key gateways between businesses and consumers. It sets objective criteria for designating so‑called gatekeepers and then imposes a list of obligations and prohibitions on them. ^[5]

A digital service is presumed to be a gatekeeper if, among other things, it:

Has at least 45 million monthly active end‑users and 10,000 yearly business users in the EU for each of the last three financial years; and
Is operated by a company with at least €75 billion in market capitalisation or significant EU turnover. ^[6]

Apple is already designated as a gatekeeper for several of its products:

iOS, the App Store, and Safari were designated in September 2023.
iPadOS followed in April 2024. ^[7]

The new question for regulators is whether Apple Ads (its advertising platform) and Apple Maps (its mapping and location service) should now join that list.

Why Apple Ads and Apple Maps Are Under EU Scrutiny

The Commission’s latest action is driven by concern that advertising and mapping platforms can serve as powerful chokepoints in the digital economy:

Apple Ads sits inside Apple’s ecosystem, particularly in the App Store and other Apple services. Regulators want to know whether Apple can use that position to favour its own advertising products or restrict rivals.
Apple Maps provides location and local business information, potentially acting as an intermediary between business users (for example, restaurants, shops and service providers) and end‑users looking for directions or nearby services. ^[8]

According to reports citing Commission officials, the EU believes that Apple’s notifications show both services meet the quantitative thresholds necessary for gatekeeper consideration and therefore merit a closer, case‑by‑case review. ^[9]

A formal gatekeeper designation would mean Apple Ads and Apple Maps must follow the DMA’s detailed list of “dos and don’ts”, designed to prevent self‑preferencing, discriminatory access and unfair tying or bundling of services.

Apple’s Counter‑Argument: Ads Is Small, Maps Is Not a Gateway

Apple is pushing back hard.

In statements cited in multiple reports and filings, the company makes two core arguments: ^[10]

Apple Ads is not dominant in EU online advertising
- Apple says its advertising business has a “minimal share” of the EU ad market when compared with giants such as Google, Meta, Microsoft, TikTok and X.
- The company stresses that it does not rely on cross‑service data—that is, it claims not to fuel Apple Ads with user data from other Apple products or third‑party services in ways that would give it an unfair advantage.
Apple Maps lacks key gatekeeper characteristics
- Apple argues that Apple Maps’ usage in the EU is low relative to rivals like Google Maps and Waze.
- It also says the service does not provide crucial “intermediation” functions that would make it a powerful gateway between businesses and consumers—such as operating a marketplace‑like environment where businesses pay for prominence or where ranking could decisively shape demand.

In essence, Apple is telling Brussels: these services may be large enough to cross the basic thresholds, but they do not have the entrenched market power or gatekeeper role that the DMA is meant to regulate.

The company has now submitted formal rebuttal documents to the Commission’s pre‑designation notices, signalling that it is prepared for a detailed legal and economic argument over how the DMA should be interpreted in these newer areas. ^[11]

Why the EU Cares: The Strategic Importance of Ads and Maps

From the Commission’s perspective, bringing advertising and mapping services into the DMA framework is about closing potential loopholes in how Big Tech can influence digital markets:

Targeted advertising is central to how online platforms make money and shape user experiences. If a company that already controls a mobile ecosystem also controls key advertising inventory inside that ecosystem, regulators fear it could steer ad spend toward its own properties or limit measurement data for rivals. ^[12]
Mapping and local discovery platforms influence how consumers find nearby businesses, travel routes and services. A dominant mapping service could in theory prioritise certain partners, display own‑brand services more prominently, or limit access to data for competing apps that rely on location and POI (points of interest) information. ^[13]

By testing Apple Ads and Apple Maps under the DMA, the EU is effectively probing the edges of Apple’s ecosystem—beyond the App Store and iOS—and asking how many of its services should be covered by structurally similar rules.

A Broader Clash: Apple vs. Brussels Over the DMA

Today’s developments do not come in isolation. They sit on top of a long‑running confrontation between Apple and EU regulators over the DMA:

In April 2025, the Commission issued its first DMA non‑compliance decisions, hitting Apple with a €500 million fine and Meta with a €200 million fine over alleged violations related to app store and data practices. ^[14]
Apple has repeatedly argued that some DMA requirements undermine user privacy and security and may delay new features for EU customers. In a detailed public statement in September, the company said the law was already causing feature delays and making the app experience “riskier” and less consistent between regions. ^[15]
Around the same time, Apple urged the EU to reconsider—or even repeal—DMA rules, claiming they distort competition and make it harder for technology companies to operate efficiently in Europe. ^[16]
In October, Apple escalated the dispute by lodging a broad legal challenge against the DMA at the EU’s General Court, arguing that the regime unlawfully forces changes to the iPhone, App Store and iMessage that go beyond what is necessary to protect competition. ^[17]

Against this backdrop, the new potential gatekeeper designations for Apple Ads and Apple Maps look less like an isolated enforcement step and more like the next front in a rolling regulatory war between the company and the EU.

What a Gatekeeper Label Would Mean for Apple Ads and Apple Maps

If the Commission ultimately designates Apple Ads and Apple Maps as gatekeepers, the services would have to comply with the DMA’s core obligations. While the exact requirements would depend on the Commission’s final decision and any implementing specifications, practical implications could include: ^[18]

For Apple Ads

Greater data transparency for advertisers
Apple could be required to give business users more detailed and standardised access to performance and user data relating to campaigns, subject to privacy law.
Limits on combining data across services
The DMA restricts gatekeepers from merging personal data from different services without explicit consent. This could further constrain how Apple uses data from iOS, App Store, Apple ID and other services to optimise targeting and measurement.
No self‑preferencing in ad placement or measurement tools
If Apple offers tools that compete with third‑party ad tech or measurement providers within its ecosystem, regulators may demand clear, non‑discriminatory terms.

For Apple Maps

Fair access for business users and rival services
Businesses that appear in Apple Maps endpoints (for example, restaurants, shops or mobility providers) could gain stronger rights to access ranking, review and traffic data and to interact with users on fair and transparent terms.
Restrictions on favouring own services
Apple might have to ensure that service suggestions within Maps—like routing to own‑brand services or partners—do not unfairly disadvantage competing apps or platforms.
Interoperability expectations
Regulators could push for more open interfaces that allow third‑party services to plug into Apple Maps data or features, again subject to privacy and security safeguards.

For Apple, this would mean re‑architecting not only the technical layers of these services but also commercial rules, contracts and product design choices—all on EU timelines and under Commission supervision.

What This Means for EU Users, Developers and Advertisers

While the DMA is primarily a competition law, the consequences for everyday users and businesses could be significant:

EU consumers may ultimately see more choice in mapping and advertising‑supported apps if gatekeeper rules curb self‑preferencing and make it easier for rivals to compete on Apple devices.
Developers and advertisers could gain stronger leverage to negotiate with Apple, particularly around access to analytics data, ranking transparency, and the ability to direct users to alternative payment or service channels.
At the same time, Apple continues to warn that complying with overlapping DMA obligations could slow the rollout of new features and introduce more complex user flows, especially around consent prompts and app distribution. ^[19]

The outcome of the Ads and Maps review will therefore shape not just Apple’s regulatory burden but also the future design of Apple’s ecosystem in Europe.

What Happens Next

The timeline from here is relatively clear:

The 45‑working‑day clock started ticking once the Commission received Apple’s notifications on 27 November 2025, putting a decision deadline in early 2026. ^[20]
During this period, EU officials will analyse usage data, market structure and Apple’s rebuttals to determine whether Apple Ads and Apple Maps indeed meet the DMA’s qualitative gatekeeper criteria. ^[21]
If either service is designated, Apple will then have six months to adapt its products, business terms and internal processes to comply—on top of the DMA obligations it already faces for iOS, the App Store, Safari and iPadOS. ^[22]

Given Apple’s ongoing court challenge to the DMA, more legal appeals are all but certain if the Commission expands gatekeeper status to Apple Ads or Apple Maps. For now, though, Brussels has made clear that it intends to test the full reach of its new digital rulebook, and Apple has signalled that it will fight every step it considers overreach.