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ARTICLE · 10 DECEMBER 2025

Key Takeaways From The CMA's First Round Of SMS Designations

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Macfarlanes LLP

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With the entry into force of the Digital Markets, Competition and Consumers Act 2024 (the DMCCA) on 1 January 2025, the UK's new digital markets competition regime (DMCR) went live.

United KingdomAntitrust/Competition Law

The CMA's designations of both Apple and Google as having "strategic market status" were a watershed moment for the regulation of digital markets in the UK, with both online search and mobile ecosystems joining the list of the UK's regulated sectors. In this article, we take a look at the decisions – picking out some key points of interest and considering their wider implications for the UK's new digital markets competition regime.

With the entry into force of the Digital Markets, Competition and Consumers Act 2024 (the DMCCA) on 1 January 2025, the UK's new digital markets competition regime (DMCR) went live. The regime introduced the concept of "Strategic Market Status" (SMS), which applies to firms designated by the CMA as holding "substantial and entrenched market power" (SEMP) and occupying a "position of strategic significance" in relation to a "digital activity" (or "digital activities", comprising multiple, interrelated activities). As the first year of the

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