The DMCC Act gives the Competition and Markets Authority a standing digital-markets regime. The CMA may designate a firm as holding Strategic Market Status in a digital activity and then impose tailored conduct requirements and pro-competition interventions on it — including, in principle, obligations around interoperability and data access. It also modernises UK consumer-protection enforcement.
DMCC Act 2024
Statute United Kingdom
The DMCC Act is the United Kingdom’s answer to the problem that general competition law moves too slowly for digital markets. Rather than litigating each abuse, the CMA may designate a firm as holding Strategic Market Status in a defined digital activity and then impose conduct requirements on it directly — obligations that can, on the face of the statute, reach interoperability, data access and fair dealing with business users.
- Designation first, obligations after - SMS is the gate; the conduct requirements are tailored to the designated activity.
- Interoperability is in scope - the Act contemplates requirements about how a designated firm deals with other businesses, which is the doorway a data obligation would come through.
- Pro-competition interventions - the CMA can go further than conduct rules where it finds an adverse effect on competition.
Why a travel report catalogues it
The State of UK Travel APIs was written to test what happens to an industry that Britain never mandated. The finding was stark: the market averages 27.7, seven of fourteen organizations publish no machine-readable contract, and Travelport — one of three companies intermediating world airline distribution, headquartered in Britain — scores 26.2, twenty-seven points below its American counterpart Sabre at 53.3.
Britain has already proved the alternative works. The CMA Open Banking Order produced a published standard, a directory, conformance testing and a market of API-first entrants in three years. The DMCC Act is the nearest instrument that could do the same thing in travel — conduct requirements on a designated intermediary could in principle reach the interoperability and portability that ATOL and the Package Travel Regulations deliberately do not.
Nothing in travel has been designated, and nothing is imminent. The European Union’s Digital Markets Act has already designated a travel intermediary as a gatekeeper, which is the closest precedent anywhere.
The entry is here because forecasting this sector requires knowing which instruments could bind, not only which ones do. On the evidence of Open Banking, the UK is the one market in the travel quartet with both the legal machinery and the demonstrated precedent to change its own published surface by regulation.
Referenced in API Evangelist papers
This regulation shows up in my published research. These reports read the machine-readable evidence provider by provider — and put this regulation in the context of a real sector.
The State of UK Travel APIs
The nearest instrument that could reach interoperability in travel intermediation — untested there, in a market where a British GDS publishes twenty-seven points below its American counterpart.
