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The Digital Markets Act (DMA) is an ex-ante regulatory framework that exists to enhance contestability and fairness in the European Union’s digital markets. As the sole enforcer of the regulation, the European Commission (Commission) faces legal challenges regarding the interpretation of the scope and doctrinal value of the act. This article examines the early stage of implementation of the DMA, focusing on key legal and doctrinal issues, mainly through the lens of the Commission’s designation decisions and the General Court’s judicial review. Additionally, the article explores the implications of an expansionist interpretative approach to how gatekeepers are designated, linking it to policy goals of open infrastructure. By analysing these developments, this study argues that the DMA is forming its own normative framework beyond competition law. The DMA’s long-term impact on digital markets and EU platform governance remains critical, as the DMA’s policy goals should be interpreted in the light of market constructivism and business reality.  Keywords: digital platform, regulation, DMA, TikTok, infrastructure, ecosystem

The First Steps of the DMA: A Nascent Doctrinal Framework