Competition Law and Governance of Digital Market Maps

1. Introduction

Digital market maps are structured representations of how digital markets are organised. They identify the relevant platforms, users, suppliers, intermediaries, complementary services, data flows, algorithms, infrastructure, switching points and competitive relationships within a digital ecosystem.

A digital market map may show, for example:

Users → App Store → App Developers → Payment System → Advertising → Data Analytics → Cloud Infrastructure

or:

Consumers → Search Engine → Vertical Search Services → Advertisers → Data Providers

Competition law increasingly requires authorities to look beyond a conventional one-product/one-market model. Digital businesses frequently operate multi-sided markets, ecosystems and interconnected platforms in which control over one layer can affect competition in several adjacent markets.

The European Commission currently treats services such as Google Search, Google Shopping, Google Maps, Google Play, Android, Amazon Marketplace, Apple App Store, Meta services and Microsoft's LinkedIn/Windows as distinct but interconnected core platform services under the Digital Markets Act framework.

2. Meaning of a Digital Market Map

A digital market map can be defined as:

A structured analytical model identifying the participants, competitive relationships, dependencies, data flows, technological layers and points of market power within a digital ecosystem.

It is therefore broader than simply defining the relevant product market.

Traditional market analysis

A traditional competition analysis may ask:

What product or service is being supplied, and who competes with whom?

Digital market mapping asks additional questions:

1. Who controls the platform?
2. Who supplies complementary products?
3. Which users are on each side?
4. What data flows between the participants?
5. Which infrastructure is indispensable?
6. Are users multi-homing?
7. Are there switching costs?
8. Does the platform rank or classify competitors?
9. Does it control access to customers?
10. Can the platform use information obtained from business users to compete against them?

Thus, digital market mapping is both a market-definition tool and a governance tool.

3. Legal Framework

A. Abuse of Dominance

Digital market maps help identify:

• dominant positions;
• exclusionary conduct;
• discriminatory access;
• tying;
• bundling;
• self-preferencing;
• predatory pricing;
• refusal to deal;
• discriminatory ranking;
• exploitative data practices;
• restrictions on interoperability.

In India, these issues principally arise under Sections 4 and 19 of the Competition Act, 2002.

B. Anti-Competitive Agreements

Mapping can reveal horizontal and vertical relationships involving:

• platform agreements;
• exclusivity;
• parity clauses;
• resale-price restrictions;
• information exchange;
• algorithmic coordination;
• distribution restrictions;
• API restrictions.

Sections 3(1) and 3(4) of the Competition Act are particularly relevant.

C. Merger Control

Digital market maps are particularly important for mergers because two companies may have relatively small individual revenues but control strategically important:

• datasets;
• APIs;
• operating systems;
• app stores;
• cloud infrastructure;
• advertising technology;
• AI models;
• digital marketplaces.

A transaction can therefore eliminate a potential competitor even where traditional market-share analysis understates the competitive significance of the target.

4. Components of a Digital Market Map

4.1 Platform Layer

Identify the central platform:

• search engine;
• marketplace;
• social network;
• app store;
• operating system;
• payment platform;
• cloud service;
• advertising exchange.

4.2 User Layer

Digital platforms generally have multiple user groups.

For example:

Google Search

• consumers;
• advertisers;
• publishers;
• vertical-search providers;
• content providers.

The competitive conditions affecting one group can influence the others.

4.3 Data Layer

The map should identify:

• consumer data;
• transaction data;
• behavioural data;
• location data;
• search data;
• advertising data;
• business-user data;
• inferred data.

Data may become a competitive input even when it is supplied without monetary payment.

4.4 Infrastructure Layer

Infrastructure can include:

• cloud computing;
• operating systems;
• payment infrastructure;
• app stores;
• telecommunications networks;
• APIs;
• authentication systems;
• identity systems.

Control over infrastructure may create bottlenecks.

4.5 Algorithmic Layer

The map should identify algorithms controlling:

• ranking;
• recommendation;
• pricing;
• search results;
• advertising allocation;
• seller visibility;
• content moderation;
• access to consumers.

This is particularly important where algorithmic decisions can favour the platform's own products.

5. Major Competition Concerns

5.1 Self-Preferencing

A vertically integrated platform may place its own service above competing services.

For example:

Search Platform → Ranking Algorithm → Own Vertical Service

The competitive concern arises when the platform controls the gateway through which consumers reach rival services.

The European Commission's Google Search enforcement under the DMA illustrates this concern. In July 2026, the Commission found Google in breach of DMA obligations concerning preferential treatment of its own services in Search.

6. Six Major Case Laws

Case 1: Google Search (Shopping) — European Union

Google Search (Shopping), Case AT.39740 / Google and Alphabet v Commission

The European Commission found that Google had abused its dominant position by systematically giving prominent placement to its own comparison-shopping service while applying less favourable treatment to competing comparison-shopping services.

The General Court upheld the Commission's essential findings in Google and Alphabet v Commission, Case T-612/17.

Competition significance

The case demonstrates that a digital market map cannot stop with:

Google Search vs other search engines.

It must examine the relationship between:

General Search → Ranking → Comparison Shopping → Merchant Traffic → Advertising

Principle

Control over one digital gateway may confer competitive advantages in an adjacent market.

Relevance to digital market maps

The case establishes the importance of mapping:

• gateway control;
• ranking mechanisms;
• downstream competitors;
• traffic flows;
• data advantages;
• consumer access.

7. Case 2: Google Android — European Union

Google Android, Case AT.40099

The European Commission investigated Google's Android ecosystem and identified restrictions involving:

• Google Search;
• Google Play;
• Android operating systems;
• device manufacturers;
• mobile browsers.

The Commission found several practices abusive, including restrictions connected with pre-installation and distribution.

The General Court subsequently upheld most of the Commission's findings while adjusting the fine.

Competition significance

Android demonstrates that a digital market cannot necessarily be treated as one isolated market.

The relevant map is closer to:

Android OS
↓
Google Play
↓
Apps
↓
Search
↓
Advertising
↓
Consumer Data

Principle

Contractual restrictions imposed at one layer of a digital ecosystem can affect competition at neighbouring layers.

8. Case 3: Google Android — India

Umar Javeed & Others v Google LLC & Another

The Competition Commission of India investigated Google's Android ecosystem and imposed a substantial penalty in 2022.

The CCI identified several interconnected markets involving:

• licensable mobile operating systems;
• app stores;
• general web search;
• browsers;
• online video hosting;
• digital assistant services.

The CCI imposed a penalty of approximately ₹1,337.76 crore in its Android mobile-device case.

Competition significance

This is particularly important for digital market mapping in India because the CCI did not simply analyse Android as an isolated software product.

It considered relationships between:

Android → Play Store → Search → Browser → OEMs → App Developers → Users

Principle

A dominant digital ecosystem can leverage control in one market to protect or expand its position in connected markets.

9. Case 4: Google Play Store — India

XYZ v Google LLC & Others

The CCI's Google Play Store proceedings examined the relationship between:

• app stores;
• app developers;
• payment processing;
• users;
• Google's billing system.

In October 2022, the CCI imposed a penalty of approximately ₹936.44 crore concerning Google's Play Store policies.

Competition concern

The market map becomes:

App Developer → Play Store → Payment System → Consumer

If the same undertaking controls both:

1. access to users; and
2. payment infrastructure,

competition may be affected through mandatory or restrictive payment arrangements.

Principle

Platform governance rules can themselves constitute an important competition-law instrument.

10. Case 5: Epic Games v Apple — United States

Epic Games, Inc. v Apple Inc., 67 F.4th 946 (9th Cir. 2023)

The dispute concerned Apple's App Store ecosystem, including:

• iOS;
• App Store distribution;
• in-app purchasing;
• payment processing;
• app developers;
• consumers.

The litigation demonstrated the importance of examining the complete ecosystem rather than looking only at the individual application.

Digital market map

iOS → App Store → App Distribution → Payment → Consumer

Competition significance

The case illustrates disputes concerning:

• platform access;
• alternative payment systems;
• app distribution;
• commissions;
• restrictions on steering consumers;
• control over complementary products.

The broader lesson is that a platform's contractual architecture can materially affect competitive opportunities for downstream businesses.

11. Case 6: United States v Google — Search and Advertising

United States v Google LLC

The U.S. Department of Justice's antitrust litigation concerning Google's search distribution practices focuses on relationships among:

• general search;
• browsers;
• mobile devices;
• default agreements;
• advertising;
• user traffic.

The case is important because search competition cannot be analysed solely through a simple list of search engines.

The relevant map includes:

Device → Browser → Default Search → Search Queries → User Data → Advertising Revenue

Competition significance

Distribution arrangements may become strategically important because control over default access can affect:

• consumer discovery;
• query volumes;
• data accumulation;
• advertising scale;
• competitor entry.

12. Case 7: Facebook/Meta — Germany

Bundeskartellamt v Facebook/Meta

The German competition authority's proceedings concerning Facebook's collection and combination of user data examined the relationship between:

• Facebook;
• other Meta services;
• third-party websites;
• user data;
• advertising;
• social-networking services.

The case demonstrated that competition analysis can intersect with data governance.

Digital market map

User → Facebook/Meta → Third-Party Data → Combined Data → Advertising → Revenue

Principle

Data practices may become competition-relevant when control over data contributes to market power or reinforces an entrenched ecosystem.

13. Case 8: Microsoft/Teams — European Union

Microsoft Teams — European Commission

The European Commission investigated Microsoft's tying/bundling of Teams with Microsoft 365 and Office 365.

The investigation examined the relationship between:

Productivity Software → Microsoft 365 → Teams → Enterprise Customers

The Commission ultimately accepted commitments intended to address competition concerns.

Significance

The case demonstrates how a dominant firm's position in one digital ecosystem can potentially be used to strengthen a complementary service.

It illustrates the importance of mapping:

• installed customer base;
• complementary software;
• interoperability;
• switching costs;
• licensing;
• distribution channels.

14. Comparative Case-Law Table

15. Digital Market Mapping and Market Definition

Traditional competition law often starts with the relevant product market.

Digital markets require a more sophisticated sequence:

Step 1 — Identify the digital activity

Example:

Online search.

Step 2 — Identify the ecosystem

Search may connect to:

• advertising;
• maps;
• shopping;
• travel;
• video;
• AI;
• browsers.

Step 3 — Identify the sides of the platform

For example:

Consumers ↔ Search Platform ↔ Advertisers

Step 4 — Identify dependencies

Who depends upon whom?

Step 5 — Identify bottlenecks

Examples:

• app stores;
• operating systems;
• search engines;
• payment systems;
• APIs;
• cloud infrastructure.

Step 6 — Identify data flows

Determine:

• who generates data;
• who collects it;
• who controls it;
• who can access it;
• whether competitors can obtain comparable data.

Step 7 — Identify competitive feedback loops

For example:

More Users → More Data → Better Service → More Users

This may produce data-driven network effects.

16. Network Effects

Digital market maps must identify both direct and indirect network effects.

Direct network effect

More users make the service more valuable to other users.

Example:

Social Network

More users → greater social value → more users.

Indirect network effect

More users attract complementary suppliers.

Example:

App Store

More consumers → more developers → more applications → greater consumer attraction.

These effects can create substantial entry barriers.

17. Multi-Homing

Digital market maps should establish whether users can use several platforms simultaneously.

Single-homing

A user uses only one platform.

Multi-homing

A user uses several competing platforms.

Multi-homing can reduce market power, while strong switching costs and ecosystem integration can discourage it.

Examples include:

• multiple payment applications;
• multiple marketplaces;
• multiple social networks;
• multiple cloud providers.

18. Data as a Competitive Asset

Data may generate several forms of competitive advantage:

1. Scale advantage

More users generate more information.

2. Quality advantage

More data can improve algorithms.

3. Targeting advantage

Better behavioural information can improve advertising.

4. Feedback advantage

Better service attracts more users, generating more data.

This creates:

Data → Algorithmic Improvement → Users → More Data

Competition authorities therefore increasingly need to map data flows, not merely monetary transactions.

19. Algorithmic Governance

A digital market map should identify who controls the algorithm.

Important questions include:

• Who determines ranking?
• Who determines recommendations?
• Are competitors ranked differently?
• Are platform products favoured?
• Can sellers manipulate rankings?
• Are prices automatically adjusted?
• Does the algorithm use competitors' commercially sensitive information?

Algorithmic governance therefore intersects with:

• abuse of dominance;
• collusion;
• discrimination;
• self-preferencing;
• consumer protection.

20. Interoperability

Interoperability is another major governance issue.

A dominant platform may control:

• APIs;
• messaging protocols;
• operating-system functionality;
• payment systems;
• authentication;
• data portability.

The European Commission's current DMA work illustrates the importance of interoperability: in 2026 it issued measures concerning interoperability with Android capabilities and access to Google Search data for third-party search engines.

21. Access and Essential Facilities

Some digital infrastructures can become potential bottlenecks.

Examples include:

• app stores;
• payment rails;
• cloud infrastructure;
• operating systems;
• identity infrastructure;
• dominant APIs;
• advertising exchanges.

A market map helps determine whether refusal of access could materially foreclose competitors.

However, not every important digital platform automatically constitutes an essential facility. The legal requirements of the applicable jurisdiction must still be satisfied.

22. Digital Market Maps and Merger Control

Market mapping is particularly important in acquisitions involving:

• startups;
• AI companies;
• data companies;
• advertising technology;
• cloud platforms;
• cybersecurity;
• digital payments.

Traditional turnover thresholds may fail to capture the competitive significance of a young company with:

• valuable data;
• emerging technology;
• a growing user base;
• potential to become a disruptive competitor.

The map should therefore identify potential competition, not only current competition.

23. Remedies

Competition authorities may use several remedies.

Structural remedies

• divestiture;
• separation of business units;
• ownership restrictions.

Behavioural remedies

• non-discrimination;
• interoperability;
• data access;
• transparency;
• prohibition of self-preferencing;
• restrictions on tying.

Platform-design remedies

• choice screens;
• default changes;
• API access;
• data portability;
• steering rights.

The European DMA represents a broader move toward ex ante governance of major digital platforms. The Commission currently designates multiple core platform services across Alphabet, Amazon, Apple, Booking, ByteDance, Meta and Microsoft.

24. India-Specific Governance

For India, digital market maps should be analysed principally through:

Competition Act, 2002

Relevant provisions include:

• Section 3 — anti-competitive agreements;
• Section 4 — abuse of dominant position;
• Section 19 — inquiry into agreements and dominance;
• Section 20 — combination inquiries;
• Section 26 — investigation procedure;
• Sections 27 and 28 — remedies.

The CCI's Google Android and Google Play Store proceedings demonstrate the application of these principles to complex digital ecosystems.

The CCI has also continued examining digital ecosystems, including an Android TV matter in which it approved Google's settlement proposal in 2025.

25. Digital Market Maps and the Ex-Ante/Ex-Post Divide

A major development is the movement from purely ex-post competition enforcement toward ex-ante digital regulation.

Ex-post model

The authority waits for conduct and then determines:

Has competition law been infringed?

Ex-ante model

The regulator identifies a powerful digital intermediary and establishes rules before competitive harm becomes entrenched.

The UK's DMCC regime, effective from January 2025, provides the CMA with powers concerning Strategic Market Status, conduct requirements and pro-competition interventions.

This makes market mapping an ongoing regulatory activity rather than a one-time exercise.

26. Governance Model for Digital Market Maps

A comprehensive regulatory framework can be represented as:

Digital Ecosystem

↓

Identify Platforms

↓

Identify Users & Business Users

↓

Map Data Flows

↓

Map Infrastructure

↓

Map Algorithms

↓

Identify Bottlenecks

↓

Assess Network Effects

↓

Assess Switching Costs

↓

Assess Multi-Homing

↓

Identify Vertical Integration

↓

Identify Potential Foreclosure

↓

Assess Market Power

↓

Competition-Law Intervention

↓

Behavioural / Structural / Interoperability Remedy

27. Key Legal Issues Emerging from Digital Market Mapping

A. Market definition

Whether conventional relevant-market tools adequately capture ecosystem competition.

B. Dominance

Whether network effects and data advantages create durable market power.

C. Self-preferencing

Whether a platform favours its own downstream products.

D. Tying

Whether access to one service is conditioned on another.

E. Data advantage

Whether exclusive access to data materially disadvantages competitors.

F. Interoperability

Whether competitors can effectively interact with the dominant platform.

G. Algorithmic discrimination

Whether ranking or recommendation systems disadvantage competitors.

H. Switching costs

Whether users can realistically migrate to competing platforms.

I. Killer acquisitions

Whether acquisition eliminates future competitive threats.

J. Ecosystem leveraging

Whether power in one market is transferred to another.

28. Importance of the Concept

The principal importance of digital market maps is that they change the unit of competition analysis.

Instead of asking only:

"Who sells the same product?"

competition law increasingly asks:

"Who controls the digital ecosystem through which users, businesses, data, infrastructure and complementary services interact?"

This is particularly significant for ecosystems controlled by large platforms.

The CMA's current digital-market investigations illustrate this continuing shift: its active work includes Google's search and search-advertising services, Google's and Apple's mobile platforms, and Microsoft's business-software ecosystem.

29. Conclusion

Governance of digital market maps represents an evolution from conventional product-market analysis toward ecosystem-based competition analysis.

A proper digital market map should capture:

1. Platforms
2. Users
3. Business users
4. Data
5. Algorithms
6. Infrastructure
7. APIs
8. Network effects
9. Switching costs
10. Multi-homing
11. Vertical integration
12. Bottlenecks
13. Potential competitors
14. Complementary services
15. Competitive dependencies

The Google Shopping, Google Android, Google Play Store, Epic Games v Apple, United States v Google, Facebook/Meta and Microsoft Teams proceedings demonstrate different ways in which control over a digital ecosystem can influence competition.

Accordingly, digital market mapping is not merely a descriptive exercise. It can serve as the foundation for market definition, dominance analysis, merger review, investigation design, remedy selection and ex-ante digital-platform governance. The modern regulatory approach increasingly recognises that competitive harm may arise not from a single isolated product, but from the architecture of the entire digital ecosystem.