On October 22, 2025, the CMA confirmed its proposed designation of both Apple and
Google as firms with strategic market status (SMS) in their
respective mobile platforms. This followed the designation of Google as an SMS
firm in online search and search advertising on October 10.

These designations have been made under the UK's new Digital
Markets Competition Regime (DMCR), which was introduced on January
1, 2025, and occur in the context of parallel actions in Europe,
Japan, and the United States. No further investigations have yet
been launched under the DMCR and there is a question mark over the
regime's future given the UK Government's focus on cutting
regulatory red tape in a whole of Government effort to encourage
inward investment (including from US tech companies).

The CMA's finding of SMS (which requires only that the firm
in question has substantial and entrenched market power and a
position of 'strategic significance,' a lower standard than
the traditional antitrust notion of 'dominance') was
expected in both cases.

Following designation, and subject to any potential appeals by
the companies concerned, the CMA will now move to the next phase,
which involves consideration of the following potential
remedies:

Commenting on the designations in Mobile Ecosystems, the
CMA's Chief Executive, Sarah Cardell, wrote:

"These designations mean the CMA can consider
proportionate, targeted interventions for both Apple and Google, to
ensure that consumers and businesses that rely on these companies
can have confidence that they're treated fairly."

This mirrors language adopted by the CMA Press Office in
regard to Search and Search Advertising:

"This designation means the CMA can consider
proportionate, targeted interventions so that UK businesses and
consumers have more choice and control over how they interact with
Google's search services."

These statements, together with amended road maps published
earlier in the year, clearly telegraph an intention to take a
restrained approach to CRs, focused on choice screens, data
portability, interoperability and ranking, with a large number of
additional CRs put on the long finger and the more intrusive PCIs
now completely off the table.

The CMA is arriving quite late to the party, with the European
Commission, the United States, and Japan already pushing ahead.