DMA Innovation 

In a challenging global environment, the EU is intensely debating its competitiveness and innovativeness. An endeavour to improve its performance in these respects must include a critical review of key elements of the Union's legal framework, with the GDPR and the recent, or impending, "Digital Acts"-Data Act, DSA, DGA, DMA, AI Act-taking centre stage. These Acts regulate digital business models and frontier technologies, viz. subjects for which, inter alia, the Draghi Report has diagnosed particular relevance to, and deficits in, the EU's global competitiveness. Against this background, but also in the context of its first regular evaluation due in May 2026, the present contribution attempts to take initial stock of how the Digital Markets Act performs on innovation. It approaches this complex topic from several perspectives by reflecting on what "innovation" means in the first place and how the DMA, and pertinent examples from EU law more generally, frame this concept; surveying relevant, DMA-specific empirical data available to date; discussing case law originating from the enforcement of both the DMA and general EU competition law; asking how innovation-related findings in these cases interact towards a guiding concept for DMA enforcement; analysing how key DMA provisions could be retrofitted for the Gatekeepers' evolving business activities in the field of artificial intelligence ("A"); and summarizing the results in theses. Far from claiming comprehensiveness, these perspectives indicate that there are two sides of the coin to "DMA innovation", namely the Act's current impact on the innovativeness of EU markets and modifications to the DMA which may help to optimize said impact.