AWS and Azure under EU Scrutiny: The Lock-in is Wobbling

28 June 2026

5 min read

On June 25, 2026, the European Commission published a preliminary ruling: Amazon Web Services and Microsoft Azure are set to be designated as gatekeepers under the Digital Markets Act. For the first time, the regulation targets cloud infrastructure itself. If your operations run on either of these hyperscalers, set the headline aside for a moment and pull out your contracts instead.

Key Takeaways

First DMA application to the cloud: The Commission provisionally designated AWS and Azure as gatekeepers on June 25. A final decision is still pending, and both companies may submit responses beforehand.
The catch lies in the process: AWS and Azure don’t meet the DMA’s standard thresholds. The Commission is classifying them anyway, arguing they serve as a critical gateway between businesses and their customers.
Architecture will feel the impact: Data portability, interoperability, and the end of silent lock-in mechanisms will determine whether the regulation becomes a real catalyst for switching providers.

What Brussels Actually Decided on June 25

The Commission hasn’t imposed any penalties – this is a preliminary assessment. AWS and Azure are the first cloud services to be considered under the Digital Markets Act’s gatekeeper mechanism. Until now, the regulation has targeted app stores, messengers, or search engines, leaving the underlying infrastructure untouched.

What Is a Gatekeeper Under the Digital Markets Act?

A gatekeeper is a major platform operator designated by the EU Commission as a critical gateway between business customers and end users. Once designated, stricter obligations around fairness, interoperability, and data access apply. Violations can result in hefty fines – up to a double-digit percentage of the company’s global revenue.

The path to this decision is particularly noteworthy. The DMA sets clear thresholds for automatic designation: at least 7.5 billion euros in annual revenue within the European Economic Area or a market capitalization of 75 billion euros, plus 45 million active end users and over 10,000 active business customers per year. As standalone platforms, AWS and Azure don’t cleanly meet these criteria. Instead, the Commission is taking a qualitative approach, focusing on market position rather than raw numbers. This makes the case a landmark: if market dominance suffices, the threshold debate becomes secondary.

The Commission’s reasoning is straightforward: AWS and Azure act as a critical gateway between businesses and their customers in the EU, and their significance continues to grow.

Paraphrased from the EU Commission’s preliminary position, June 25, 2026

The announcement doesn’t specify a date for the final decision. Typically, designated gatekeepers are given a six-month transition period to comply with the obligations. For now, those planning ahead should expect a window rather than a fixed deadline. That’s enough time for thorough preparation but not enough for a full-scale, pressure-driven replatforming.

Three Obligations That Are Reshaping Architecture

The DMA isn’t some abstract competition paper. For gatekeepers, it translates into concrete technical requirements – three of which directly impact platform teams.

Data portability without punitive fees. A gatekeeper must enable business customers to effectively extract their data. In practice, this means continuous export options, documented formats, and predictable egress costs. Those currently paying five-figure sums to pull data from a single region now have a compelling argument.
Interoperability at the interfaces. Services shouldn’t artificially lock out competitors. For multi-cloud setups, this is the real game-changer. An API that only works within its own ecosystem becomes a regulatory liability.
No more silent self-preferencing. A gatekeeper’s own managed service can’t be secretly favored over a competitor’s offering on the same platform. This applies equally to databases, AI endpoints, and marketplace logic.

10 Percent

Non-compliance with the Digital Markets Act can result in fines of up to 10 percent of global annual revenue. That’s the leverage making these obligations impossible for gatekeepers to ignore.

Source: Digital Markets Act, Article 30

The market has seen this direction before – from another regulation. The Data Act already forces cloud providers to gradually reduce switching fees until they disappear entirely. The DMA goes a layer deeper for designated gatekeepers: where the Data Act lowers switching costs, the DMA tackles the structural market power behind them. For platform teams, this means reading both regulations together. The egress question is no longer just about costs-it’s about compliance.

None of these obligations are enforceable yet. But each sets a clear direction for platforms to follow. For operators, this is a rare opportunity: demands that once bounced off in contract negotiations are now written into law.

What Your Setup Needs to Review Now

The most honest preparation is unglamorous. It happens in contracts and runbooks – not press releases. Four areas deserve attention before the final decisions land.

First, exit clauses. Many cloud contracts detail onboarding meticulously but dismiss offboarding in a single sentence. That’s exactly where the lock-in the DMA targets takes root. Second, egress budgets. If you don’t know the cost of a full data extraction, you can’t plan a switch or negotiate effectively. Third, true multi-cloud capability. An application that’s technically portable but clings to proprietary services isn’t really portable at all. Fourth, data retention. Are keys, backups, and logs stored in a way that lets you reconstruct them without the hyperscaler’s stack?

This work pays off regardless of the outcome. A setup that masters clean exits negotiates better and isn’t left exposed if a provider fails. Those who’ve never tested a switch discover – too late – that their backup strategy was just wishful thinking. For insights on structuring multi-cloud costs, see Cloud Brokers Over Chaos: Cutting Multi-Cloud Costs by 30 Percent.

The gatekeeper debate shifts negotiating power slightly back toward customers. It doesn’t dictate which platform you build on – but it forces a second question back into the conversation: how you’ll exit.

Frequently Asked Questions

Are AWS and Azure now officially DMA gatekeepers?

Not yet. The European Commission published a preliminary position on June 25, 2026. Both companies can respond before a final decision is made.

Why does the DMA apply even though the thresholds aren’t met?

The Digital Markets Act allows for designation through a qualitative approach. The Commission justifies this based on the market position of both cloud services as critical gateways – not on fixed revenue or user numbers.

What changes concretely for my cloud architecture?

If the designation stands, data portability, interoperability, and the ban on self-preferencing will take center stage. In practice, this means predictable egress costs, open interfaces, and a documented exit pathway.

How much time would the providers have to comply?

The announcement doesn’t specify a final date. Under the DMA, gatekeepers typically have six months after designation to meet obligations.

Should I wait for the final decision before taking action?

No. Reviewing exit clauses, egress budgets, and multi-cloud readiness is worthwhile regardless of the outcome. This preparation strengthens every negotiation and contingency plan.