Document Type : Research Paper

Authors

1 Ph.D. Candidate in Private Law, Shahid Beheshti University, Tehran, Iran.

2 Assistant Professor, Department of International Trade, Intellectual Property, and Cyberspace Law, Faculty of Law, Shahid Beheshti University, Tehran, Iran

10.22054/jplr.2026.90212.2980

Abstract

: This article conducts a comparative analysis of the European Union’s Digital Markets Act (DMA) and Iran’s regulatory framework for digital platforms. The DMA, enacted in 2022, adopts an ex-ante regulatory approach toward gatekeepers with the aim of ensuring competitiveness and fairness in digital markets. It imposes a set of obligations on dominant platforms to prevent anti-competitive behavior and enhance transparency. In contrast, Iran’s regulations—including the policies of the Supreme Council of Cyberspace—focus primarily on consumer protection and data privacy and lack specific provisions for regulating digital gatekeepers.The study examines the provisions of the DMA, including transparency requirements and interoperability obligations, and compares them with Iran’s legal framework. It further assesses whether Iran’s current regulations are sufficient to address similar competitive challenges or require reform. The analysis indicates that the DMA’s preventive approach may serve as a model for improving competition and fairness in Iran’s digital sector. By evaluating these regulatory frameworks, the research contributes to a better understanding of how competitive environments can be fostered in the digital space.

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