On 9 December 2022, the European Commission published its draft DMA Implementing Regulation for consultation, together with the proposed Notification Form for "gatekeepers". The text deals with notifications, submissions and practical arrangements in relation to future Commission decisions under the DMA. Despite a laudable attempt to balance the need for the Commission to act swiftly and effectively and the rights of "gatekeepers", we think the Commission’s proposal needs a recalibration in order to adequately safeguard companies’ rights of defense. The context The Digital Markets Act ("DMA") entered into force on 1 November 2022 and will start applying on 2 May 2023 (see The Digital Markets Act (DMA) goes live). It aims at improving contestability and fairness in digital markets and

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