The Proceeding in Brief
On April 27, 2026, the European Commission addressed preliminary findings to Alphabet in case DMA.100220, opening a public consultation on draft interoperability measures under Article 6(7) of the Digital Markets Act. The Commission has until July 27, 2026 — six months after opening specification proceedings on January 27 — to issue a binding final decision. The core obligation: Alphabet must provide third-party AI service providers "free and effective interoperability" with the same Android capabilities currently reserved for its own Gemini assistant.
The draft measures are structured around four distinct technical layers. Their combined breadth has no precedent in DMA enforcement.
What the Draft Measures Actually Require
The Commission's preliminary findings in DMA.100220 propose four interoperability categories:
- Invocation — Rival assistants must be activatable via custom wake words and system-wide gestures, including the long-press home handle, with contextual data accessible at the moment of invocation.
- Context — Third parties must receive centralised access to on-device application data, keyboard integration, and the ability to surface proactive suggestions in the same fashion as Gemini.
- App actions — Competing AI services must be able to autonomously interact with installed applications and issue OS-level commands, including brightness adjustments and do-not-disturb activation.
- Resource access — Rivals must access on-device AI models and execute tasks at guaranteed performance and responsiveness levels.
The scope matters because Android commands roughly 58% of Europe's mobile OS market by device usage as of May 2026, according to StatCounter data. Any AI assistant that cannot achieve system-level integration on Android is competing from a structurally weaker position on the continent's dominant mobile platform.
The Pro-Competitive Case
The Commission's logic is defensible. Google's ability to pre-install Gemini with OS-level privileges that no rival receives by default creates a structural advantage beyond ordinary product competition. The DMA was designed precisely for this scenario: a gatekeeper leveraging control of a designated core platform service (Android) to preference a linked downstream product (Gemini) in a rapidly growing adjacent market.
"Availability is not the same as access — a downloadable rival assistant doesn't compete in the same market as one embedded at OS level."
An AI assistant restricted to a sideloaded application lacks access to wake-word activation, real-time contextual signals, and deep application integration. It operates at a shallower level of the stack. If Article 6(7) has any force in the era of AI assistants, DMA.100220 is precisely what it was built for.
Where Proportionality Gets Complicated
The draft measures nonetheless draw genuine technical criticism that goes beyond Google's self-interest. The four-layer framework requires concurrent, persistent hotword detection for multiple assistants on device digital signal processors, along with write-level integration into core productivity applications like Gmail and Calendar granted to any qualifying third-party assistant.
The Information Technology and Innovation Foundation, in formal consultation comments submitted in May 2026, warned that granting deep system access to third parties "whose practices may not meet [Android's] exceptionally high standards" creates serious consumer privacy exposure. The ITIF also flagged a free-rider problem: mandating access to Google's on-device AI infrastructure without compensation weakens the platform-level innovation incentives that produced it.
The European Centre for International Political Economy identified a structural tension: functional-equivalence mandates may be technically incompatible with Android's distributed OEM architecture, where the same interoperability requirement must be applied consistently across hundreds of device configurations with heterogeneous security models. That could make the measures either unenforceable in practice or push Google toward centralising Android's trust architecture — an ironic outcome for a regulation intended to open the platform.
Estonia's Lens: Interoperability Is Harder Than It Looks
Estonia has built and exported what is arguably the world's most replicated government interoperability infrastructure. X-Road — the data exchange layer underpinning Estonia's e-governance stack — has been adopted in Finland, Namibia, Ukraine, and dozens of other governments. The consistent lesson: interoperability mandates succeed when they specify precise technical interfaces alongside security requirements and accountability frameworks. They fail when they mandate outcomes while leaving the engineering path undefined.
Estonia's Consumer Protection and Technical Regulatory Authority (TTJA) serves as the national Digital Services Coordinator for EU digital law implementation, and the Estonian Competition Authority (ECA) oversees DMA compliance within the jurisdiction. Estonian policymakers have consistently argued at Council level that regulators must "refrain from over-regulating online service providers" and must carefully weigh consumer welfare against competitive objectives — a position Estonia's digital governance record makes credible.
The DMA.100220 draft measures sit in exactly the tension Estonia's tradition highlights: ambitious outcome mandates, a tight six-month window, and no published technical security framework for the most sensitive capability layers. That combination risks producing compliance litigation rather than actual market opening.
What the Commission Should Do Before July 27
The Commission's core objective — preventing Android from structurally tilting AI assistant competition toward Gemini — is sound competition policy. The question is whether a single binding specification decision is the right instrument for a four-layer AI stack integration problem of this technical complexity.
A proportionate approach would adopt the invocation and default-assistant requirements immediately, where the competitive harm is clearest and the engineering is well-understood; stage the context and app-actions layers pending a joint technical specification process with defined security standards; and require Alphabet to publish an implementation roadmap before full compliance deadlines are enforced.
Non-compliance with the final decision carries potential fines of up to 10% of Alphabet's global annual turnover under Article 26 of the DMA — tens of billions of euros at Alphabet's scale. That ceiling gives Alphabet strong incentive to engage seriously. It gives the Commission equal incentive to ensure the July 27 decision is technically defensible, not merely legally sufficient. The AI assistant market is genuinely contested; the regulation should open it without inadvertently breaking the platform it seeks to govern.