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ORCID

Arletta M. Gorecka – 0000-0001-6555-4264

Keywords

abuse of dominance; exploitative abuse; anti-steering provisions; digital platforms; App Store; gatekeeper power; consumer harm; two-sided markets; Digital Markets Act (DMA); ecosystem lock-in; platform regulation

Abstract

This case comment analyses the European Commission’s 2024 decision fining Apple €1.84 billion for imposing anti-steering provisions on music streaming apps in the App Store. The decision marks a significant development in the application of Article 102 TFEU to digital platform ecosystems. By characterising Apple’s conduct as an exploitative abuse of dominance, the Commission addressed restrictions that limited consumer information, increased subscription prices, and reduced user choice within the iOS environment. The case illustrates the hybrid nature of Article 102 TFEU, bridging exploitative and exclusionary theories of harm in two-sided digital markets. It also highlights structural features such as network effects, ecosystem lock-in, and gatekeeping power that reinforce platform dominance. Finally, the decision is examined in light of the Digital Markets Act (DMA), revealing the emerging dual framework of ex post competition enforcement and ex ante regulation shaping EU digital market governance.

Acknowledgements

Funding

This article received no outside funding.

Declaration of Conflict of Interests

The author declared no potential conflicts of interest with respect to the research, authorship, and publication of this article.

Declaration about the scope of AI utilisation

The author did not use AI tools in the preparation of this article.

Page Count

31

Received Date

19.02.2026

Accepted Date

21.04.2026

DOI

10.7172/1689-9024.YARS.2026.19.33.8

JEL Code

K21, L40, L86, D43

Publisher

University of Warsaw

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