The European Commission Heard from Developers

Do you have any comments or observations on the current list of core platform services?

Many tools on the current list of platform services are vital for developer success and should not be overregulated or changed.

Google Play StoreEssential developer gatewayGoogle takes on the burden of security and privacy enforcement by rejecting millions of risky apps to safeguard users while giving vetted developers access to a trusted platform.For example, on Google Play, a developer can pay as little as $25 to open an account, access powerful software development kits, and bring an app to millions of global users within days. Google's high security and privacy standards establish trust from users-trust that is passed down to the apps listed on the Play Store. The Play Store vets apps to ensure they're safe, free of malware, and that they secure user data and payments. Last year alone, Google rejected 2.36 million apps from its store because they didn't meet its standards. Overregulating app stores will make it harder for small teams to create new apps, reach customers, and succeed.

Alphabet's online advertising service is also highly beneficial to developers. Leveraging Google Ads is a simple, effective, and inexpensive way to attract users to an app. Not to mention, Google Ads and Analytics use anonymous consumer data to find people who are actually interested in the app's content. AdMob is also vital, as it's a simple way for developers to increase revenue by publishing relevant ads alongside their apps. Some developers have even seen a 60% increase in ad revenue when using AdMob.

Browser InconsistencyExcludes Microsoft EdgeThe DMA's core platform list creates unequal treatment by regulating Chrome and Safari while overlooking Microsoft's forceful tactics to capture browser market share through Edge.It is also troubling that Chrome and Safari are listed as core platform services, but Microsoft Edge is not. Microsoft does everything it can to steer consumers into using its Edge browser. When a user gets a new Windows device and tries to download a different browser, for example, a Microsoft pop-up appears that claims Edge is the most secure browser and makes the user confirm that they still want to download a different one. Similarly, after every Windows update, users must confirm again that they want to use an alternative browser. Even after successfully switching from Edge, some capabilities still remain in the default Edge browser, like opening a PDF document. This is frustrating for consumers, as their information, such as shipping address and payment information, may be stored in their preferred browser. For developers, interoperability is key, but not all web apps run the same on different browsers. Pushing consumers to adopt Edge as their default browser impacts developers who optimize their apps for Chrome or Safari.

When reviewing the list of core platform services, the Commission should consider how innovative, time-saving, and accessible the Play Store and Google's ad services are for small and independent developers. The Commission should also ensure it does not let competitors off the hook by leaving their services off the list.

Do you have any comments in relation to the impact and effectiveness of the DMA?

The DMA significantly impacts small and independent developers. Its regulations severely disadvantage small teams compared to larger competitors, and complying with its rules is extremely difficult, expensive, and time-consuming.

Sideloading ConcernsBypassing security checksBy mandating sideloading and multiple app stores, the DMA erodes security standards and forces resource-strapped developers to choose between compliance costs and product innovation.First, requiring major app stores to allow link-outs to third-party sites and largely unrestricted sideloading creates serious security concerns. Apps can bypass Google and Apple's vetting and security checks, making users more likely to encounter scams, data breaches, or malware. In the end, the security risks erode consumer trust in apps and app stores.

Additionally, allowing third-party app stores on Google Play and the App Store puts small developers at a disadvantage. Take the Chinese app ecosystem, which has hundreds of smaller app stores. Instead of simply building two versions of their apps (one for Android and one for Apple) to reach all users, developers must build multiple versions for multiple platforms-each with its own coding and technical requirements, review processes, and terms of service. This may be a light lift for large app developers, but small teams lack the time, money, and resources to create multiple versions of their products or hire new developers to do so. In this way, creating an ecosystem with many app stores puts small and independent developers at a severe disadvantage.

The DMA also introduces significant compliance obligations that increase costs and administrative burdens for developers. A recent report finds that complying with the DMA will cost U.S. businesses over $1 billion. While large companies can absorb these costs, smaller teams face real economic strain. And with so much to comply with, small developers may shift resources from product development to legal compliance, slowing the creation of new apps and services.

Do you have any comments or observations on the current list of obligations (notably Articles 5 to 7, 11, 14 and 15 DMA) that gatekeepers have to respect?

In addition to the above comments, there are several issues with Article 5.

Data Processing RestrictionsReduces the value of advertisingRestricting anonymous data usage in advertising removes small businesses' most cost-effective growth tool, while mandating alternative payment options introduces security vulnerabilities into trusted app ecosystems.First, prohibiting gatekeepers from “(a) process[ing], for the purpose of providing online advertising services, personal data of end users using services of third parties that make use of core platform services of the gatekeeper” will fundamentally change the way app-based businesses advertise and grow their companies. Data-powered online advertising is an effective and inexpensive way to grow a company, especially for small businesses with limited resources and advertising budgets. Advertisers do not exploit individual user data; instead, they leverage aggregated and anonymous data points to better understand audiences. Restricting data usage means online ads will become less effective, harming the small app-based businesses that need them to grow and compete.

Additionally, preventing a gatekeeper from requiring the use of its payment services raises serious privacy and security concerns. The Play Store, for example, offers safe and secure payment processing services that developers can use on their apps for in-app purchases and subscription fees. Allowing developers to use other payment processing methods opens the door to bad actors. Users' payment information may be subject to less secure and even dangerous processing systems, breaking the existing trust in the app ecosystem.

Conclusion

Small and independent developers are the innovation engine, creating apps and services that drive competition and enrich the digital ecosystem. The DMA risks stifling this creativity by imposing disproportionate burdens that large gatekeepers can easily absorb. We urge the Commission to create an environment where small developers can innovate, reach users efficiently, and thrive while ensuring fair and contestable digital markets.