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European Commission's €200 million DMA fine

"consent or pay" does not meet DMA requirements

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€200M DMA — the first "consent or pay" fine

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A10 — European Commission’s €200 million DMA fine: “consent or pay” does not meet DMA requirements

Category: DMA art. 5(2) / combining data across services / “consent or pay” Company/companies: Meta Platforms Ireland (Facebook, Instagram) Years: March 7, 2024 – November 2024 (infringement period), April 23, 2025 (fine) Status: First DMA fine in history; Meta has announced an appeal to the EU General Court Card ID: A10


Metadata

FieldValue
Country/regionEuropean Union (European Commission)
Year revealedApril 23, 2025 (fine announcement)
Years the practice ranMarch 7, 2024 (DMA obligations take effect) – November 2024 (Meta introduced a new model)
Total fineEUR 200,000,000
CurrencyEUR
Legal basisDMA art. 5(2) (Digital Markets Act, EU Regulation 2022/1925)
Whistleblower/discovererNOYB, BEUC, Dutch AP (complaints); European Commission ex officio (formal proceedings March 25, 2024)
Number of people affectedAll Facebook and Instagram users in the EEA — ~260 million active users
Status (today)Meta has announced an appeal; new “less personalized ads” model from November 2024 is under Commission review

TL;DR

On April 23, 2025, the European Commission imposed on Meta Platforms Ireland the first ever fine under the Digital Markets Act (DMA): €200 million. The basis was a breach of art. 5(2) DMA — the provision that bars gatekeepers from combining users’ personal data across different core platform services without explicit consent. In November 2023, Meta rolled out the “consent or pay” model: users had only two choices — consent to behavioral targeted advertising (with data combined across Facebook and Instagram) or pay €9.99–12.99 per month for an ad-free version. The Commission found that this is not freely given consent within the meaning of the DMA.

Starting March 7, 2024, the DMA imposed on the 6 “gatekeepers” (Meta, Apple, Google, Amazon, Microsoft, ByteDance) a series of obligations, including art. 5(2): if a user refuses consent to data combination, the platform must offer a free alternative that is clearly less personalized but equivalent. Meta argued that a paid €9.99/month subscription was that “alternative.” The Commission sided with the EDPB (Opinion 08/2024, April 17, 2024): payment is not equivalent to free use — a user who does not want targeting must have a free, less personalized option.

In November 2024 Meta modified the model: it introduced a third option — free use of Facebook/Instagram with contextual (non-personal) advertising based, for instance, on what you are currently viewing rather than on a profile. The Commission is still evaluating whether the new model meets the DMA — a decision is expected in 2026.

The €200 million fine is the first DMA sanction in history — alongside the €500 million fine for Apple over anti-steering (App Store). Symbolically, it opens the era of DMA enforcement. Meta has filed an appeal. Joel Kaplan (Chief Global Affairs Officer at Meta since January 2025, previously Deputy Chief of Staff for Policy in the George W. Bush administration 2006–2009): “The Commission is forcing us to change our business model, effectively imposing a multi-billion-dollar tariff on Meta while requiring us to offer an inferior service.”

For EU citizens, the decision confirms the direction set in A09: social media platforms have no right to combine your data across different products without freely given consent. A subscription in exchange for privacy is not freely given consent if the price of refusal is losing free access to the underlying service. The case has fundamental significance for the future of the advertising model in Europe.


Timeline

  • September 14, 2022 — announcement of the Digital Markets Act (DMA) — EU Regulation 2022/1925.
  • November 1, 2022 — DMA enters into force.
  • May 2, 2023 — DMA begins to apply fully, but without enforcement against gatekeepers (preparatory period).
  • September 6, 2023 — the European Commission designates 6 gatekeepers: Meta, Apple, Amazon, Alphabet (Google), Microsoft, ByteDance (TikTok). For Meta: Facebook, Instagram, WhatsApp, Messenger, Meta Marketplace, Meta Ads.
  • October 2023 — in response to the DPC fine (A09), Meta announces a “consent or pay” model — €9.99/month (web) or €12.99/month (iOS/Android).
  • November 28, 2023 — NOYB files complaints against Meta’s “consent or pay” model with multiple DPAs.
  • February 29, 2024 — BEUC, Verbraucherzentrale Bundesverband (German consumer association) and other consumer organizations file complaints with the European Commission.
  • March 7, 2024 — DMA obligations become binding for gatekeepers.
  • March 25, 2024 — the European Commission opens formal proceedings against Apple, Google and Meta for DMA non-compliance. In Meta’s case: charge of breaching art. 5(2) through the “consent or pay” model.
  • April 17, 2024EDPB Opinion 08/2024 — a fundamental opinion: “consent or pay” models in the case of large online platforms generally do not meet the consent requirements under the GDPR.
  • July 1, 2024 — the European Commission issues preliminary findings: Meta’s model infringes DMA art. 5(2).
  • November 2024 — Meta introduces a third option: free use of Facebook/Instagram with context-based ads (less personalized) instead of behavioral ads. At the same time, it lowers the subscription price for the ad-free version: from €9.99/12.99 to €5.99/7.99 per month.
  • April 23, 2025 — the European Commission announces the first non-compliance decisions in DMA history:
    • Apple: €500 million for breach of art. 5(4) (App Store anti-steering)
    • Meta: €200 million for breach of art. 5(2) (consent or pay)
  • April 23, 2025 — Meta announces an appeal to the EU General Court.
  • June–July 2025 — Meta files a formal appeal.
  • To date (04.2026) — the Commission is assessing whether Meta’s new November 2024 model complies with the DMA; a decision is expected in 2026.

Mechanism

DMA in a nutshell — why it exists and what it regulates

The Digital Markets Act is an EU regulation adopted in 2022 as a response to the problem of Big Tech dominance in digital markets. Traditional competition law (art. 102 TFEU — abuse of a dominant position) requires lengthy proceedings, often 10+ years. Google Shopping case (2017) — 7 years; Microsoft browser case (2004) — 6 years. During that time, markets change.

The DMA introduces an ex ante approach — instead of waiting for an abuse, it imposes up front on gatekeepers (companies with annual turnover >€7.5 billion and >45 million monthly users in the EU) a set of prohibitions and obligations. Gatekeepers:

  • Meta (Facebook, Instagram, WhatsApp, Messenger, Marketplace, Ads)
  • Apple (App Store, iOS, Safari)
  • Alphabet (Google Search, Android, Chrome, YouTube, Google Maps, Google Play)
  • Amazon (Amazon Store, Amazon Ads)
  • Microsoft (Windows, LinkedIn)
  • ByteDance (TikTok)
  • (Later additions: Booking.com, X)

Art. 5(2) DMA — what it says

The exact text: “The gatekeeper shall not process, for the purpose of providing online advertising services, personal data of end users (…) unless the end user has been presented with the specific choice and has provided consent within the meaning of Article 4, point (11), and Article 7 of Regulation (EU) 2016/679.”

Broken down:

  1. A gatekeeper may not process personal data for advertising across different services…
  2. unless the user has given specific consent
  3. Consent must meet the GDPR standard art. 4(11) and art. 7 — “freely given, specific, informed and unambiguous”
  4. If the user refuses consent, the gatekeeper must make available a less personalized but equivalent alternative

How Meta tried to work around art. 5(2)

After A09 (January 2023 — the DPC fine for “performance of contract”), Meta needed a new basis for processing. After a series of attempts (legitimate interest → rejected by the EDPB in October 2023), in October/November 2023 it introduced the “consent or pay” model:

Option A: accept targeting (consent to combining FB and Instagram data for ads) — you stay on the free model.

Option B: pay €9.99/month (web) or €12.99/month (iOS/Android, factoring in the 30% Apple/Google commission). You get an ad-free version — plus an additional account under the same subscription.

Meta’s argument:

  • This gives users a choice — consistent with the GDPR and DMA.
  • The paid subscription is equivalent — the user gets the full service, just without ads.
  • The price (€9.99) is market-based — comparable to Netflix, Spotify.

Why the Commission rejected this model

The Commission (relying heavily on EDPB Opinion 08/2024) argued:

Argument 1: No third option. Art. 5(2) DMA requires that a user refusing consent be offered a “less personalized but otherwise equivalent alternative”. Meta offered only a binary choice — consent for free or payment for no ads. A free, less personalized option was missing.

Argument 2: Payment is not an equivalent. If the alternative to consent is a payment many times higher than ARPU (Meta’s Average Revenue Per User in the EU is ~€60/year = €5/month, while the subscription price of €9.99–12.99/month = more than 2× ARPU), then this is not a free choice. The user is de facto forced into consent.

Argument 3: “Chilling effect” on fundamental rights. The Commission: “If a user is faced with a choice between consent and losing access to a service they use to maintain contact with family and friends — this has little to do with ‘free’ choice within the meaning of the GDPR and DMA.” The concept of power imbalance — gatekeepers have a structural advantage.

Argument 4: Changing the default state. The DMA is meant to protect users from being pressured into consent. Meta changed the model in October 2023, forcing users into a new choice — moving from “free consent in the TOS” (previously found unlawful in A09) to “consent under threat of payment.” This is not a correction toward DMA compliance; it is an escape into another form of coercion.


Discovery

Bodies that initiated the proceedings

Unlike the €1.2 billion fine (A07) and the €390 million fine (A09), which Max Schrems / NOYB initiated, the DMA case was brought ex officio by the European Commission — in line with the DMA framework, which gives the Commission exclusive jurisdiction to enforce against gatekeepers.

Nevertheless, preparatory complaints were filed by:

  • NOYB (November 28, 2023)
  • BEUC (European Consumer Organisation)
  • Verbraucherzentrale Bundesverband (German consumer association)
  • Verbraucherzentrale Nordrhein-Westfalen — a separate civil suit before the Oberlandesgericht Köln (May 2024)
  • Dutch AP, Norwegian Datatilsynet, German BfDI — complaints to the Commission

The role of the EDPB

The key moment: April 17, 2024 — the EDPB publishes Opinion 08/2024 on Valid Consent in the Context of Consent or Pay Models. This is the first formal position by an EU body that “consent or pay” models in the case of large online platforms generally do not meet the consent requirements under the GDPR.

Key findings of Opinion 08/2024:

  • “Free services” are the foundation of the internet; introducing financial barriers to refusing consent breaches the principle of voluntariness.
  • A free, less personalized alternative must be offered (DMA art. 5(2) and by analogy the GDPR).
  • Particular risk in cases of lock-in effects — Facebook/Instagram hold decades of user data, contacts and photos; migrating to a competitor is practically impossible.

How the fine came about

The sequence:

  1. March 25, 2024 — the Commission opens formal proceedings.
  2. April 17, 2024 — EDPB Opinion 08/2024.
  3. July 1, 2024 — the Commission sends preliminary findings to Meta.
  4. November 2024 — Meta introduces the third option (contextual ads).
  5. October 2024 – April 2025 — defense period; Meta files its response.
  6. April 23, 2025 — final non-compliance decision.

First publications

  • April 23, 2025 — European Commission press release (IP/25/1085)
  • April 23, 2025 — in parallel: POLITICO EU, Reuters, FT, Bloomberg
  • April 23, 2025 — Meta’s response (blog post by Joel Kaplan)
  • April 23–24, 2025 — commentary: Taylor Wessing, Bird & Bird, Noerr, Hunton, Kluwer Competition Law Blog

Key people

European Commission

  • Margrethe Vestager — Executive Vice-President of the Commission for a Europe Fit for the Digital Age and Commissioner for Competition until 2024. Lead architect of the DMA together with Thierry Breton. Although the decision was announced after her departure, the investigation was conducted under her oversight.
  • Thierry Breton — Commissioner for the Internal Market until 2024. The second architect of the DMA/DSA. He left in disagreement with Ursula von der Leyen in 2024.
  • Teresa Ribera — Executive Vice-President of the Commission for a Clean, Just and Competitive Transition (since 2024). The April 2025 fines were announced under her oversight.
  • Olivier Micol — Director at DG GROW responsible for DMA enforcement.

On Meta’s side

  • Joel Kaplan — Chief Global Affairs Officer at Meta since January 2025 (after Nick Clegg). Previously VP Global Public Policy at Facebook from 2014 and Deputy Chief of Staff for Policy in the George W. Bush administration (2006–2009). A Republican; his appointment signaled Meta’s rightward shift ahead of Trump’s return to power. Author of Meta’s statement following the fine.
  • Nick Clegg (until end of 2024) — VP Global Affairs at Meta, responsible for relations with the Commission during the investigation.
  • Rob Sherman — Chief Privacy Counsel at Meta.
  • Markus Reinisch — VP Public Policy Europe at Meta.

Activists and organizations

  • Max Schrems / NOYB — provided the complaints and the legal basis.
  • Ursula Pachl, Monique Goyens — BEUC.
  • Anu Talus — EDPB Chair, signed Opinion 08/2024.

Experts

  • Cristina Caffarra — competition law economist (CEPR), one of the most influential commentators on the DMA.
  • Alba Ribera Martínez — EU competition lawyer, author of analyses in the Kluwer Competition Law Blog.
  • Damien Geradin — professor of competition law at Tilburg Law School, frequently cited.

Company response

Meta

Joel Kaplan, statement of April 23, 2025: “The European Commission is forcing us to change our business model, effectively imposing a multi-billion-dollar tariff on Meta while requiring us to offer an inferior service. And this isn’t about Europeans — it’s about protecting Meta’s European competitors at the expense of American companies.”

Meta’s arguments on appeal:

  • The “Subscription for No Ads” model of November 2023 was legally permissible in light of the CJEU ruling C-252/21 Meta v. Bundeskartellamt of July 2023, in which the CJEU expressly noted that “a paid alternative may in some cases be appropriate.”
  • The Commission applied EDPB Opinion 08/2024 retroactively, even though the model itself was introduced in October 2023.
  • Personalized advertising is the foundation of the free internet — without it, many European media outlets, websites and small businesses will not survive.
  • The infringement period was short (March 7, 2024 – November 2024 = 8 months), and the fine does not reflect this proportionately.

Practical measures:

  • Introduction of the third option in November 2024 (described above).
  • Lowering the subscription price from €9.99/12.99 to €5.99/7.99 per month (web/iOS-Android).
  • Appeal to the EU General Court.

Political reactions

Donald Trump, Truth Social, April 23, 2025 (a few days after taking office for his second term): “EU’s fines on American tech companies are a form of taxation without representation. We will respond with tariffs if this doesn’t stop.” The statement ignited a debate about EU-US trade escalation.

Margrethe Vestager (already a former commissioner, on a panel at Davos 2025): “Europe cannot afford to tolerate the world’s largest companies breaking our laws. This isn’t ‘anti-American’ — it’s ‘pro-European’.”

Certain member states (including Ireland and Luxembourg — headquarters of Big Tech) expressed skepticism about such swift decisions; France, Germany, the Netherlands — clearly backed the Commission.

Markets

Meta shares fell about 1.5% after the fine was announced and quickly rebounded. Analysts: the €200 million fine, plus €500 million for Apple, signal an era of active DMA enforcement — potentially tougher than the GDPR itself.


Jurisdictions

  1. European Commission — exclusive jurisdiction over DMA enforcement
  2. EU General Court — first instance of appeal
  3. CJEU (Court of Justice) — second instance, possible preliminary references
  4. National courts — parallel consumer proceedings (e.g., OLG Köln)
  • DMA art. 5(2) — prohibition on combining data across a gatekeeper’s services without consent; requirement to offer a less personalized alternative
  • DMA art. 8(1) — general compliance obligations
  • DMA art. 13(6) — obligation to implement Commission decisions
  • DMA art. 30 — fines of up to 10% of global annual turnover, up to 20% for repeat infringements
  • GDPR art. 4(11), art. 7 — criteria for valid consent (referenced in the DMA)

Key stages

DateStage
March 7, 2024DMA obligations enter into force
March 25, 2024Formal proceedings
April 17, 2024EDPB Opinion 08/2024
July 1, 2024Preliminary findings
November 2024Meta introduces the third option
April 23, 2025Final non-compliance decision, €200 million
June 2025Meta files an appeal
  • CJEU C-252/21 Meta v. Bundeskartellamt (July 4, 2023) — a central precedent; but the Commission interpreted it differently than Meta did.
  • CJEU C-311/18 Schrems II (2020) — background for GDPR transfers.
  • CJEU C-673/17 Planet49 (2019) — criteria for valid online consent.
  • EDPB Decision 01/2023 — ban on Meta’s behavioral advertising.

Penalties and settlements

DateAuthorityAmountJurisdictionBasis
April 23, 2025European CommissionEUR 200,000,000EUDMA art. 5(2)

Maximum possible: 10% of Meta’s 2024 global turnover (~$160 billion) = ~€16 billion. The Commission imposed about 1.25% of the maximum — relatively lenient, given the infringement period (8 months) and the fact that Meta introduced fixes.

For comparison:

  • Meta’s 2024 antitrust fine: €797 million for exploiting Facebook Marketplace (breach of art. 102 TFEU, 7 years of the practice)
  • Apple’s DMA fine: €500 million

Precedents and implications

For EU law

  • The first non-compliance decision in DMA history — a milestone.
  • Confirmation that the Commission is prepared to apply DMA sanctions quickly (a year from preliminary findings).
  • Strict interpretation of art. 5(2) — payment is not equivalent to refusing consent.
  • Strengthening the role of the EDPB as a “consultant” to the Commission in DMA matters.

For US law

  • Accelerating the debate over a federal competition law (the AMERICA Act, 2022, not enacted).
  • Impact on FTC merger enforcement — the argument “Europeans are doing it, why aren’t we?”.

For Big Tech practice

  • The end of “binary consent” models — all major platforms in the EU (Meta, X, TikTok, LinkedIn, Google) must consider three-tier consent models.
  • The third option (contextual ads) is becoming the standard.
  • Subscription pricing for privacy must be reasonable relative to ARPU.
  • Impact on adtech generally — smaller ad companies may also fall under the analogy.

For other gatekeepers

Apple (€500 million for App Store anti-steering), Google (proceedings ongoing), Amazon (proceedings), ByteDance (proceedings). Each of them has parallel DMA cases.


Class actions

CaseCourtStatusValueBasis
Verbraucherzentrale NRW v. MetaOLG KölnAppealGerman UWG
Potential follow-on damagesEU national courtsIn preparationDMA art. 39 (damages)

Important: DMA art. 39 allows for private enforcement — consumers and companies can sue gatekeepers for damages resulting from DMA breaches. This may open the way for American-style class actions in the EU.


Conclusions for citizens

Portal section — practical.

What does this mean for me?

As a Facebook / Instagram user in the EU, you have three legally guaranteed options since March 2024:

  1. Consent to behavioral targeting + free use with personalized ads
  2. Paid subscription (€5.99/month web, €7.99/month iOS/Android) — no ads at all
  3. Free use with contextual ads (the new option from November 2024) — no targeting, with ads based on “the here and now” (e.g., what you are currently viewing)

The third option is often hidden — Meta does not actively promote it because it is the least profitable. You have to look for it in settings.

How to protect yourself

  1. Find the “less personalized ads” option in settings:
    • Facebook: Settings → Accounts Center → Your information → Ad preferences → “See ad options”
    • Instagram: same, via the Accounts Center
  2. If you are in the EU and don’t see the third option — this may be a DMA violation. Report it to the European Commission (there is a form on the EC website).
  3. Compare subscription prices: Meta now (since November 2024) €5.99/web; YouTube Premium €9.99/month; Spotify €9.99/month. For Meta, the subscription covers both Facebook and Instagram through the Accounts Center.
  4. Consider alternatives: Mastodon (Fediverse), BlueSky (decentralized), Pixelfed (similar to Instagram) — hosted in the EU or non-profit, with no advertising model.

What rights do I have?

DMA art. 5(2) — the right to choose between targeting and a less personalized service (without being forced to pay).

DMA art. 39 — the right to compensation for damages resulting from a DMA breach.

Order to disclose the advertising structure (DMA art. 5(9)): the gatekeeper must, on request, provide information about ad prices and publisher remuneration.

GDPR as in A09.

Where to file

  • European Commission (DMA): ec.europa.eu/competition, “DMA complaint” form
  • Poland (GDPR): UODO
  • Consumer organizations: Federacja Konsumentów, BEUC, NOYB
  • Polish Consumer Association

Note for mediators, lawyers, creators and entrepreneurs

  1. If you run a business in the EU and use Meta ads — check whether you comply with DMA art. 5(2). Many advertising firms are unaware that the new “less personalized ads” model requires reconfiguring campaigns for retargeting.
  2. For consumer mediators: the DMA case opens a new field of disputes — a consumer can now argue that they were forced into consent to targeting.
  3. For digital lawyers: DMA art. 39 opens the way to private enforcement. Poland may see the first class actions under opt-in models (requiring consent).
  4. For content creators earning from Meta ads: reducing targeting intensity may lower CPM (cost per mille) by 20–40%. It is worth diversifying revenue sources: YouTube, Patreon, your own newsletters.

Context

  • The first DMA fines in history — April 23, 2025 will be remembered in the history of digital regulation as “DMA Day One.” Together with Apple (€500 million) — a combined €700 million on a single day.
  • Meta got off relatively “lightly” — with a possible maximum of 10% of global turnover (~€16 billion), €200 million is 1.25%. The Commission explained this by: the short infringement period (8 months) + the fact that Meta introduced fixes in November 2024.
  • Joel Kaplan instead of Nick Clegg — Kaplan’s appointment (a Republican, a former Bush aide) as Chief Global Affairs Officer at Meta in January 2025 was a clear political signal: Meta was positioning itself for the incoming Trump administration. Kaplan’s statement after the fine (“a tariff on Meta”) is a natural extension of that.
  • Meta’s new November 2024 model — “contextual” ads — is a return to the pre-algorithmic era of internet advertising. Ads are based on what you are viewing at the moment (e.g., an article about cooking → an ad for a cookware pot), rather than on a user profile. Ironically, this is closer to the traditional press model — advertisers buy space next to content, rather than access to a reader profile.
  • “Consent or pay” as a business experiment — the adtech industry had been considering it for years, but no major platform dared to introduce it before Meta (October 2023). After the Commission’s decision in April 2025, several other platforms (including X/Twitter under Elon Musk) backed away from plans for similar models.
  • The economics of privacy subscriptions: Meta initially priced the subscription at €9.99/month (web) = €120/year. Meta’s Average Revenue Per User (ARPU) in the EU is ~€60/year. That means Meta was demanding 2× ARPU for refusing targeting. After criticism, this was lowered to €5.99/month = €72/year = 1.2× ARPU.
  • “Gatekeeper shopping” — in the early months of the DMA, some companies tried to escape gatekeeper status by cutting users or restructuring. Microsoft successfully reduced Edge (browser) below the threshold. Meta could not — its Facebook/Instagram are orders of magnitude above the thresholds.
  • Polish context: UOKiK (the Office of Competition and Consumer Protection) in Poland has been the Digital Services Coordinator since 2024 — coordinating DSA cases in Poland, but the DMA is the exclusive domain of the European Commission. This means Poles can only file DMA complaints in Brussels.
  • Meta’s appeal to the EU General Court — standard EU court procedures; a first-instance ruling in about 2–3 years. If Meta wins, it could be the first breach in the DMA — the scenario NOYB had warned about.
  • Verbraucherzentrale NRW (German consumer association) obtained an injunction against Meta in July 2024 in the Oberlandesgericht Köln under German unfair competition law (UWG). This is a parallel enforcement track — not DMA, but national consumer law.
  • The US reaction: the Meta €200 million case + Apple €500 million + Google (ongoing) = a significant escalation in transatlantic tensions. The Trump 2 administration (from January 2025) openly linked these fines to a trade war — threatening tariffs on European exports. Margrethe Vestager (already a former commissioner) publicly commented: “Europe is not a colony.” The case became a symbol of EU digital sovereignty.

Sources

  1. European Commission, “Commission decisions under the Digital Markets Act — Apple and Meta”, IP/25/1085, April 23, 2025. URL: https://ec.europa.eu/commission/presscorner/detail/en/ip_25_1085 (accessed: 2026-04-17)

  2. European Commission, “Digital Markets Act: Commission fines Meta €200 million”, official press release, April 23, 2025.

  3. European Data Protection Board, “Opinion 08/2024 on Valid Consent in the Context of Consent or Pay Models implemented by Large Online Platforms”, April 17, 2024. URL: https://edpb.europa.eu/our-work-tools/our-documents/opinion-board-art-64/opinion-082024-valid-consent-context-consent-or_en (accessed: 2026-04-17)

  4. Joel Kaplan, “Our Position on the European Commission’s DMA Decision”, Meta Newsroom, April 23, 2025. URL: https://about.fb.com/news/ (accessed: 2026-04-17)

  5. Taylor Wessing, “DMA in Action: European Commission imposes €200 million fine on Meta for violation of data combination rules”, April 24, 2025. URL: https://www.taylorwessing.com/en/insights-and-events/insights/2025/04/meta-fined-200-million-euro-by-eu-under-digital-markets-act (accessed: 2026-04-17)

  6. Bird & Bird, “First-ever DMA Non-Compliance Fines – Another Step in Big Tech Scrutiny”, May 2025. URL: https://www.twobirds.com/en/insights/2025/belgium/first-ever-dma-non-compliance-fines (accessed: 2026-04-17)

  7. Hunton Andrews Kurth, “European Commission Fines Apple and Meta for Non-compliance with the DMA”, April 25, 2025. URL: https://www.hunton.com/privacy-and-information-security-law/european-commission-fines-apple-and-meta-for-non-compliance-with-the-dma (accessed: 2026-04-17)

  8. TechPolicy.Press, “Understanding the Apple and Meta Non-Compliance Decisions Under the Digital Markets Act”, May 6, 2025. URL: https://www.techpolicy.press/understanding-the-apple-and-meta-noncompliance-decisions-under-the-digital-markets-act/ (accessed: 2026-04-17)

  9. Alba Ribera Martínez, “The DMA’s Teeth: Meta and Apple Fined by the European Commission”, Kluwer Competition Law Blog, April 28, 2025. URL: https://legalblogs.wolterskluwer.com/competition-blog/the-dmas-teeth-meta-and-apple-fined-by-the-european-commission/ (accessed: 2026-04-17)

  10. PwC Legal, “Enforcement of the DMA – European Commission imposes first fines under the DMA on Apple and Meta”, May 20, 2025. URL: https://legal.pwc.de/en/news/articles/enforcement-of-the-dma (accessed: 2026-04-17)

  11. “Meta’s ad business faces uncertainty in E.U. after €200 million fine”, The Current, May 1, 2025. URL: https://www.thecurrent.com/data-privacy-meta-ad-business-uncertainty-eu-200-million-fine (accessed: 2026-04-17)

  12. Regulation (EU) 2022/1925 (Digital Markets Act), Official Journal of the EU L 265/1, October 12, 2022. URL: https://eur-lex.europa.eu/eli/reg/2022/1925/oj (accessed: 2026-04-17)

  13. CJEU, judgment in case C-252/21 Meta Platforms et al. v. Bundeskartellamt, July 4, 2023.

  14. NOYB, “Facebook/Meta: Pay or Okay is Illegal”, series of communications 2023–2025. URL: https://noyb.eu/en/ (accessed: 2026-04-17)

  15. BEUC, “BEUC calls on European Commission to confirm Meta’s ‘pay or consent’ violates Digital Markets Act”, July 2024.

  16. Oberlandesgericht Köln, Verbraucherzentrale NRW v. Meta case, ruling July 2024.


Last updated: 2026-04-17 Card in database: A10_dma_200mln.md