Digital Sovereignty as De Facto Tariff? EU Fines on Big Tech and Transatlantic Tensions
By Martyna Chmura | 22 December 2025
Summary
In 2025, the European Commission imposed large fines on Apple, Meta, Google and X under competition, Digital Markets Act (DMA) and Digital Services Act (DSA) rules, signalling stricter enforcement on Big Tech.
The financial scale and concentration of these decisions mean enforcement increasingly resembles a de facto tariff regime that mainly affects United States (US) platforms, raising political sensitivity in Washington.
Over the next few years, continued enforcement is expected to intensify EU-US tensions on digital trade and influence platform strategies.
Context
Recent EU actions mark a decisive shift from rule-making to active enforcement of the DMA, DSA – the EU’s flagship Big Tech regulations designed to curb platform power, alongside competition law. In April 2025, the Commission imposed its first fines under the DMA, ordering Apple to pay EUR 500m for restricting developers from informing users about alternative payment options, and Meta EUR 200m for “consent‑or‑pay” model that did not give users a genuine choice on tracking and targeted advertising. In September 2025, Google was fined EUR 2.95b for ad-tech self-preferencing, with the Commission signalling that structural remedies may be necessary to address vertical conflicts of interest in its advertising stack. On 5 December 2025, X received a EUR 120m DSA fine for deceptive “verified” blue checkmarks, insufficient ad transparency and unjustified restrictions on researcher access to data. These decisions primarily affect a small group of US-based firms that control critical layers of Europe’s digital economy.
Implications
The fines create direct financial and compliance burdens for the firms concerned and also reshape incentives in the wider digital ecosystem. For Apple, Meta and Google, the DMA and competition decisions require changes to core business models in the European Union, including steering rules in app ecosystems, consent design, interoperability – that is, enabling rival services to interact fairly with their core platforms – and integration of ad‑tech services. Building separate technical and legal arrangements only for the EU is costly, so compliance‑driven adjustments can spill over into global product design and data practices, thereby reinforcing the EU’s regulatory influence through the so-called Brussels effect. For X, the DSA decision forces changes to verification, advertising and data‑access systems at a time of financial strain, which can affect how the platform invests in trust and safety functions in Europe. Higher expected enforcement risk raises the hurdle rate for EU‑specific investments (new services, AI features, or hardware launches), leading firms to roll out products later, on a smaller scale, or not at all in Europe. To contain exposure, firms may cap EU user acquisition or scale back aggressive growth tactics (for example, less cross‑service data integration), which indirectly affects Europe’s competitiveness as a digital market.
At the same time, enforcement under the DMA alters how digital markets are organised. Obligations to avoid self‑preferencing, support interoperability, host alternative app stores and allow third‑party services to interoperate with core platform functions reduce the scope for gatekeepers to channel users and business customers into closed ecosystems. This redistributes some control over traffic, data and commercial relationships away from a few integrated platforms towards a broader set of intermediaries, app stores and service providers, and nudges dominant firms to test new pricing and bundling strategies as traditional forms of data‑driven tying and leveraging become harder to sustain in Europe.
Politically, enforcement fuels a widening transatlantic debate. US officials and analysts frame the pattern of large fines and structural obligations as a de facto tariff regime, arguing that EU actions disproportionately target American firms and limit their commercial discretion and informing discussions about possible trade or regulatory responses. In contrast, the EU frames its approach as non-targeted and rights-driven, focused on curbing market power, strengthening user protections, and ensuring accountability for systemic platforms. Notably, this view is not universally contested in the United States: several prominent lawmakers, including Senator Bernie Sanders and Senator Elizabeth Warren, have publicly welcomed the EU’s regulatory approach and advocated for similar constraints on dominant technology firms in the US, underscoring emerging transatlantic divisions within, as well as between, political systems. Moreover, the US could credibly link future cooperation on security and industrial policy to what it regards as “proportionate” treatment of its firms, using the sanctions‑like character of fines as an argument in trade or foreign‑policy bargaining.
For European firms and business users, enforcement can expand competitive space by reducing lock-in, enabling interoperability, and clarifying data-access rules. Yet the same regulations may prompt large platforms to scale back features, APIs, or research tools in Europe to reduce compliance exposure. Over time, this contributes to a perception of the EU as a high-compliance but globally influential regulatory jurisdiction, central to digital-policy norm-setting but approached more cautiously by major platforms when planning investments, product roll-outs, and cross-market integrations.
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Forecast
Short-term (Now - 3 months)
It is almost certain that the European Commission continues to open additional DMA and DSA non-compliance probes, as early enforcement tests reveal gaps in current platform adaptations.
It is highly likely that political and industry actors in the US intensify criticism of EU enforcement and frame it as protectionist or discriminatory.
It is highly likely that major platforms will file procedural challenges while rolling out narrowly scoped compliance changes designed primarily to buy time.
Medium-term (3-12 months)
It is likely that the EU will shift toward deeper structural remedies – interoperability, data-access requirements, and alternative app-store pathways – as initial behavioral fixes fail to satisfy regulators.
It is unlikely that European SMEs will gain notable market share, though experimentation around new competitive openings will continue.
Long-term (>1 year)
There is a realistic possibility that firms maintain EU-specific product configurations to manage regulatory divergence and reduce litigation exposure.
It is likely that cumulative fines and remedies continue to act as a form of economic pressure on US platforms, with periodic spikes in transatlantic tension when new large cases are announced.
It is likely that US policymakers explore reciprocal measures, through trade, privacy or competition channels, as regulatory asymmetry persists.
