Competition Law And Ecosystem Centrality Metrics in Competition Law

1. Meaning of Ecosystem Centrality Metrics

Ecosystem centrality metrics are analytical measures used to determine how important a firm, platform, infrastructure, technology, or service is within a broader business ecosystem.

Traditional competition analysis often asks:

“How much market share does the undertaking have in the relevant market?”

Ecosystem analysis asks a broader question:

“How central is the undertaking to the functioning of several interconnected markets?”

A company may have only moderate market share in one market but still occupy a highly central position because it controls:

an operating system;

app distribution;

payment infrastructure;

cloud infrastructure;

search access;

advertising technology;

logistics;

data;

interoperability standards.

Thus:

Market share ≠ ecosystem centrality.

2. Why Ecosystem Centrality Matters

Modern digital markets frequently operate as interconnected systems.

For example:

Operating System

↓

App Store

↓

Payments

↓

Advertising

↓

Cloud

↓

Data

↓

Consumers

A firm occupying several important nodes may influence competition throughout the ecosystem.

Its centrality can create:

bargaining power;

network effects;

switching costs;

data advantages;

entry barriers;

foreclosure opportunities;

self-preferencing opportunities;

cross-market leverage.

3. Important Qualification

Ecosystem centrality is not, by itself, a separate offence under competition law.

A high-centrality position does not automatically establish:

dominance;

abuse;

monopolisation;

an anti-competitive agreement;

unlawful merger.

Instead, centrality can be evidence or an analytical input when assessing established competition-law questions.

The proper chain is:

Centrality → Market power → Conduct → Competitive effect → Consumer/innovation effect → Legal conclusion

not:

Centrality → automatic illegality.

4. UAE Competition-Law Framework

The UAE's current competition regime is principally governed by Federal Decree-Law No. 36 of 2023 Regulating Competition, supplemented by the 2026 implementing framework.

The Ministry currently lists:

Federal Decree-Law No. 36 of 2023;

Cabinet Decision No. 59 of 2026 on Executive Regulations;

2026 relevant-market guidance;

concentration thresholds;

other sector-specific competition measures.

The current UAE framework addresses:

restrictive agreements;

abuse of dominant position;

economic concentration;

market power;

anti-competitive conduct.

The law's provisions on abuse of dominance include conduct such as unjustified refusal to deal, tying, discriminatory treatment, restrictions on competitors, and conduct limiting markets, production or technological development.

Ecosystem centrality can therefore become relevant when determining whether a firm has ability to influence competitive conditions beyond a single product or service.

5. Traditional Market Share vs Ecosystem Centrality

6. Major Ecosystem Centrality Metrics

There is no single legally prescribed “ecosystem centrality score.”

Instead, competition economists can use different metrics.

A. Degree Centrality

Measures the number of direct connections a firm has.

Formula:

Degree Centrality = Direct Connections / Possible Connections

Example:

A platform connected to:

10 million consumers;

500,000 sellers;

20,000 advertisers;

100 logistics providers

has substantial direct connectivity.

7. Betweenness Centrality

Measures how often a firm sits between other participants.

Conceptually:

Firm A → Platform → Firm B

If the platform is the unavoidable intermediary, it has high betweenness centrality.

This is particularly relevant to:

marketplaces;

payment systems;

app stores;

advertising exchanges;

booking platforms.

A high-betweenness firm may possess gateway power.

8. Eigenvector Centrality

Eigenvector centrality measures not merely the number of connections but the importance of the entities to which a firm is connected.

A firm connected to many highly influential businesses may have greater ecosystem importance than a firm connected to many insignificant businesses.

Example

Platform A connects to:

major banks;

major retailers;

major advertisers;

major cloud providers.

Platform B connects to many small firms.

Both may have many connections, but A may have greater ecosystem centrality.

9. Closeness Centrality

Closeness centrality measures how quickly an undertaking can reach other participants in the ecosystem.

A highly central platform may be only a few steps away from:

consumers;

suppliers;

advertisers;

developers;

payment providers;

logistics providers.

This can indicate rapid access to ecosystem information and commercial relationships.

10. Dependency Centrality

A particularly useful competition-law concept is:

How many market participants depend upon the undertaking to reach customers or suppliers?

Possible indicators:

percentage of transactions through the platform;

percentage of sellers dependent on the platform;

percentage of traffic controlled by the platform;

percentage of payments processed;

percentage of developers dependent on an app store.

This is not a standard statutory metric, but it can help explain economic dependence.

11. Switching-Cost Centrality

Centrality becomes more important where switching is difficult.

Possible switching barriers include:

data migration costs;

contractual restrictions;

technical incompatibility;

loss of consumer history;

loss of reputation;

loss of network access;

retraining costs.

A platform may therefore become central because leaving it is expensive.

12. Data Centrality

A firm may occupy an important ecosystem position because it controls data flows.

Relevant measurements may include:

volume of data;

uniqueness of data;

frequency of data collection;

number of ecosystem participants;

ability to combine datasets;

real-time access;

data exclusivity.

Data feedback loop

More users

↓

More data

↓

Better service

↓

More users

↓

Greater centrality

This can reinforce market power.

13. Algorithmic Centrality

Algorithms can become ecosystem gateways.

A platform may control:

search ranking;

product recommendation;

advertising placement;

app ranking;

content visibility;

seller visibility.

The centrality question becomes:

Who controls the algorithm through which market participants reach consumers?

14. Gateway Centrality

Gateway centrality measures the extent to which an undertaking controls access between different ecosystem layers.

Examples:

operating system → applications;

search engine → websites;

app store → developers/consumers;

payment network → merchants/customers;

marketplace → sellers/consumers.

Gateway control may become particularly important when alternative routes are weak.

15. Ecosystem Centrality and Dominance

A high-centrality position may contribute to evidence of dominance where it demonstrates:

substantial economic power;

dependency;

barriers to entry;

network effects;

control over infrastructure;

ability to act independently of competitors or customers.

But the legal test remains jurisdiction-specific.

Centrality is evidence—not the legal conclusion.

16. Case Law 1 — Google Shopping

Google and Alphabet v Commission

Case C-48/22 P

The Court of Justice upheld the finding concerning Google's treatment of its own comparison-shopping service in general search results.

Google occupied an important gateway position because general search was a major route through which consumers accessed online information.

Ecosystem-centrality significance

The case illustrates:

Search gateway → ranking → traffic → competing services

A platform can influence downstream competition through control over an important gateway.

Principle

Control over a central access point can be relevant to competition even where the downstream service is a separate market.

17. Case Law 2 — United States v Microsoft

253 F.3d 34 (D.C. Cir. 2001)

Microsoft's dominant position in PC operating systems gave it substantial control over an important technological platform.

The case involved conduct concerning:

Internet Explorer;

Netscape;

Java;

software distribution;

operating-system integration.

Ecosystem-centrality significance

Microsoft's operating system functioned as a central layer between:

Hardware → Operating System → Applications → Consumers

This gave Microsoft an ability to influence adjacent technological markets.

Principle

Centrality within a technological architecture can facilitate leveraging into adjacent markets.

18. Case Law 3 — Microsoft v Commission

Case T-201/04

The European Commission found Microsoft liable for abuses involving interoperability information and tying.

The General Court upheld the Commission's principal findings.

Ecosystem-centrality significance

Interoperability determines whether other products can connect with the central platform.

Therefore:

Platform centrality + interoperability control = potential ecosystem leverage.

Principle

Technical control over an ecosystem interface can affect competitive conditions in complementary markets.

19. Case Law 4 — Ohio v American Express

585 U.S. 529 (2018)

American Express operated a two-sided payment platform linking:

merchants; and

cardholders.

The Supreme Court emphasised the importance of considering both sides of a transaction platform.

Ecosystem-centrality significance

Payment platforms occupy a central position connecting multiple groups.

The case demonstrates why centrality cannot be analysed only through one side of a platform.

Principle

In multi-sided ecosystems, competition analysis must account for the interdependence between platform participants.

20. Case Law 5 — Eturas

Eturas UAB v Lithuanian Competition Council

Case C-74/14

The case concerned an electronic travel-booking system through which communications concerning discount limits were distributed to participating travel agencies.

Ecosystem-centrality significance

The electronic system created a common communication infrastructure connecting competitors.

This demonstrates that a platform may become central not only as a seller but also as an information intermediary.

Principle

A central digital intermediary can influence competitive behaviour by controlling information flows.

21. Case Law 6 — Coty Germany

Coty Germany GmbH v Parfümerie Akzente GmbH

Case C-230/16

The case involved selective distribution and restrictions on sales through third-party platforms.

The Court recognised circumstances in which a supplier could restrict identifiable third-party platforms while maintaining a selective distribution system meeting the relevant conditions.

Ecosystem-centrality significance

The case shows that not every platform restriction is automatically anti-competitive.

The analysis must consider:

nature of the product;

distribution structure;

legitimate objectives;

proportionality;

actual competitive effects.

Principle

Centrality of a platform does not eliminate the need for contextual competition analysis.

22. Case Law 7 — Pierre Fabre

Pierre Fabre Dermo-Cosmétique

Case C-439/09

The case concerned a restriction that effectively prevented distributors from selling certain products online.

Ecosystem-centrality significance

The internet increasingly became a central distribution channel.

Restricting access to an important digital channel can affect:

consumer reach;

entry;

price competition;

distribution alternatives.

Principle

Control or restriction of an important distribution channel can influence market access.

23. Case Law 8 — Intel

Intel Corp. v Commission

Case C-413/14 P

The Court addressed the assessment of exclusionary rebates and the importance of economic analysis concerning foreclosure capability.

Ecosystem-centrality significance

Centrality cannot be established merely by describing a firm as “important.”

Authorities need evidence concerning:

actual competitive constraints;

foreclosure;

pricing;

customer behaviour;

alternative suppliers.

Principle

Ecosystem centrality requires economic evidence rather than purely descriptive claims about importance.

24. Ecosystem Centrality and Self-Preferencing

Suppose a marketplace:

hosts independent sellers;

collects seller data;

ranks sellers;

operates its own competing products.

It possesses centrality at several layers.

If it systematically favours its own products, the competition analysis may involve:

Centrality → gateway power → self-preferencing → rival foreclosure → consumer effects.

Google Shopping is particularly relevant to this structure.

25. Ecosystem Centrality and Tying

Suppose:

Operating System

↓

Mandatory Browser

↓

Search

↓

Advertising

A firm with high centrality at the first layer can potentially use that position to influence competition in downstream layers.

The relevant questions are:

Is there market power?

Are products separate?

Is tying imposed?

Are customers constrained?

Are competitors foreclosed?

Are there efficiencies?

Are less restrictive alternatives available?

26. Ecosystem Centrality and Refusal to Deal

A central platform may become indispensable to certain businesses.

For example:

App developer → App store → Consumer

If alternative access routes are realistically unavailable, the platform may become a critical gateway.

Competition law may then examine refusal-to-deal or access issues under the applicable legal test.

But:

High centrality alone does not automatically create an obligation to deal.

The specific jurisdictional doctrine must still be satisfied.

27. Ecosystem Centrality and Network Effects

Network effects strengthen centrality.

Positive feedback

More users

→

More sellers

→

More products

→

More consumers

→

More data

→

Better platform

→

More users

This can produce significant entry barriers.

Competition analysis therefore asks whether centrality is:

contestable;

reversible;

durable;

reinforced by exclusionary conduct.

28. Ecosystem Centrality and Multi-Homing

Multi-homing means users participate in multiple competing platforms.

Example:

A seller uses:

Amazon;

eBay;

its own website.

If multi-homing is easy, ecosystem centrality may be weaker.

If switching or multi-homing is difficult, centrality may be stronger.

Therefore:

Centrality + low switching cost = potentially contestable

while:

Centrality + high switching cost = potentially stronger market power.

29. Ecosystem Centrality and Merger Control

Centrality metrics can also be relevant in mergers.

Consider:

Dominant Platform A + Emerging Technology B

Even if B has low revenue, it may occupy an important technological position.

A merger may eliminate:

future competition;

interoperability alternatives;

innovation;

data competition.

Therefore, merger analysis may examine:

ecosystem position;

network effects;

data;

potential competition;

innovation;

dependency.

30. Ecosystem Centrality Matrix

31. Centrality Score — Analytical Model

A competition economist could construct a non-legal analytical index such as:

ECI = w₁G + w₂B + w₃D + w₄N + w₅S + w₆Data

Where:

G = gateway centrality;

B = betweenness;

D = dependency;

N = network effects;

S = switching costs;

Data = data centrality;

w = analytical weights.

Important

This is not a statutory UAE competition-law formula.

It is only an analytical tool for understanding ecosystem importance.

32. Centrality Does Not Equal Dominance

This distinction is essential.

Centrality

“How important is the undertaking within the ecosystem?”

Dominance

“Does the undertaking possess substantial market power under the applicable competition-law test?”

Abuse

“Has the undertaking used that position through prohibited conduct?”

Therefore:

Centrality → evidence

Dominance → legal/economic status

Abuse → unlawful conduct

33. Centrality Does Not Equal Market Share

Consider two companies:

Company A

60% market share in one isolated market.

Company B

25% market share but controls:

the platform;

payment system;

data;

advertising;

app distribution.

Company B may have greater ecosystem centrality, even though Company A has greater market share in the individual market.

This does not automatically mean Company B is legally dominant.

34. Centrality and Economic Dependence

Centrality becomes especially relevant when other firms cannot realistically operate without the platform.

Indicators include:

percentage of sales through platform;

percentage of customer acquisition;

platform-specific reputation;

data accumulated;

technical integration;

contractual dependence;

lack of substitutes.

This may overlap with the competition-law concept of economic dependence.

35. Centrality and Consumer Welfare

Centrality can generate significant efficiencies:

convenience;

interoperability;

lower transaction costs;

greater product variety;

improved matching;

faster innovation.

Therefore, competition authorities must not assume that centralisation is inherently harmful.

Positive centrality

Central platform → lower transaction costs → innovation → consumer benefit

Negative centrality

Central platform → exclusion → dependency → reduced competition → consumer harm

The legal analysis must distinguish between them.

36. Centrality and Competition Remedies

Where an ecosystem problem is established, possible remedies may include:

interoperability;

data portability;

non-discrimination;

access obligations;

restrictions on self-preferencing;

limits on exclusivity;

structural separation;

divestiture;

monitoring.

The remedy should address the competitive mechanism, not merely the existence of centrality.

37. UAE Application

Under the UAE's current competition framework, ecosystem centrality can be useful particularly for analysing:

Digital platforms

marketplaces;

payment platforms;

food-delivery platforms;

advertising platforms.

Infrastructure

telecommunications;

logistics;

ports;

cloud services.

Data-driven markets

AI;

digital advertising;

e-commerce.

Economic concentration

A merger can be assessed not merely through traditional market shares but also through whether it creates or strengthens control over strategically important ecosystem connections.

The UAE's current framework includes relevant-market guidance and specific 2026 measures concerning certain digital-platform arrangements, showing that competition governance is increasingly responsive to transformed market structures.

38. Practical Ecosystem-Centrality Test

A competition authority can ask:

Question 1

How many participants depend on the undertaking?

Question 2

How important are those participants?

Question 3

Does the undertaking sit between otherwise disconnected market participants?

Question 4

Can participants realistically bypass it?

Question 5

How costly is switching?

Question 6

Does the undertaking control essential data?

Question 7

Does it control ranking or visibility?

Question 8

Does it operate in adjacent markets?

Question 9

Can it transfer market power across those markets?

Question 10

Has it actually engaged in exclusionary conduct?

39. Exam-Oriented Framework

ECM Framework

E — Ecosystem

Identify the connected markets.

C — Centrality

Measure gateway, network and dependency position.

M — Market Power

Determine whether centrality translates into substantial competitive power.

C — Conduct

Identify tying, self-preferencing, exclusion, refusal, discrimination, etc.

E — Effects

Assess foreclosure, innovation, price, quality and consumer choice.

R — Remedy

Select proportionate intervention.

40. Short Examination Answer

Ecosystem centrality metrics in competition law refer to quantitative and qualitative measures used to assess how important an undertaking is within an interconnected economic or digital ecosystem. Traditional competition analysis focuses heavily on market share and relevant-market boundaries, whereas ecosystem analysis may additionally examine network centrality, gateway control, betweenness, dependency, switching costs, data control, interoperability and cross-market connections.

Important comparative authorities include United States v Microsoft, Microsoft v Commission, Google Shopping, Ohio v American Express, Eturas, Pierre Fabre, Coty Germany, and Intel. These cases illustrate different aspects of platform power, interoperability, multi-sided markets, digital distribution, information flows, gateway control and evidence-based assessment.

The principal legal caution is that ecosystem centrality is not itself an offence. A highly central firm may provide substantial efficiencies and consumer benefits. Competition-law intervention requires a connection between centrality, market power, specific conduct and an anti-competitive effect under the applicable legal framework.

In the UAE, Federal Decree-Law No. 36 of 2023 provides the current competition framework, supported by the 2026 implementing regulations and relevant-market guidance. Ecosystem-centrality analysis can therefore serve as a useful economic tool when examining dominance, restrictive conduct and economic concentrations in interconnected and digital markets.

41. Ultra-Rapid Revision

Ecosystem → Centrality → Gateway → Network Effects → Data → Dependency → Switching Costs → Interoperability → Market Power → Dominance → Conduct → Foreclosure → Innovation → Consumer Welfare → Remedy

One-line formula

Ecosystem Centrality + Market Power + Exclusionary Conduct + Competitive Effect = Potential Competition-Law Concern

Key distinction

Centrality tells us where a firm sits in the ecosystem; dominance tells us about its market power; abuse concerns what it does with that power.