Guidelines on the interplay between the DMA and the GDPR

In October 2025, the European Commission and the European Data Protection Board (EDPB) launched a public consultation to gather feedback on draft guidelines on the interplay between the Digital Markets Act (DMA) and the General Data Protection Regulation (GDPR). BEUC welcomes this initiative as an essential step to clarify interconnections between the DMA and GDPR.    

There is an urgent need to increase cooperation between authorities for an effective implementation and enforcement of the EU digital rulebook (e.g. GDPR, DMA, Digital Services Act, the Unfair Commercial Practices Directive, AI Act). While the DMA foresees cooperation between authorities in the framework of its High-Level Expert Group , we need clarity on how laws are interpreted and applied. This is essential to ensure consistency and provide greater legal clarity for stakeholders and consumers across borders.  

BEUC supports several points in the draft guidelines, notably: 

• The need to establish a clear connection between the GDPR and the DMA and clarifying that, whilst different in purpose, these two laws are complementary.
• Gatekeepers must demonstrate compliance with the DMA by implementing measures that protect the integrity of their hardware or operating system, and by keeping an exhaustive list of the measures put in place and the rationale thereof.
• Recognizing the existence of a system of cooperation between authorities to ensure coherent enforcement of data-related obligations where different regulatory frameworks intersect.

Below you'll find the summarized version of our contribution to the public consultation.