Opening Pandora’s Interface: AI Assistants and the DMA
If the Digital Markets Act (DMA) is going to force open the most sensitive parts of modern smartphones, it will have to answer a basic question it has so far sidestepped: how much security risk is too much in the name of interoperability?
In January, the European Commission opened proceedings to define Google’s duties under the DMA for Android. The focus: how much access third-party AI services should get to features like hotword detection, on-screen content, and audio-output monitoring—capabilities Google currently reserves for its own AI assistants. The Commission has six months to issue a specification decision, and its announcement already signals where it may land.
This marks the first time the Commission has applied Article 6(7) DMA—the interoperability obligation for operating systems—to AI-assistant features. It has already deployed the same provision against Apple. In March 2025, it issued two specification decisions requiring Apple to open iOS connectivity features—near field communication (NFC), Wi-Fi, Bluetooth pairing, and notification forwarding—to third-party devices. In doing so, the Commission developed a narrow “integrity” doctrine that sharply limits when gatekeepers may restrict interoperability on security and privacy grounds.
The key question is whether that doctrine can hold when applied to the more sensitive system access that AI services demand. I argue that the Commission should offer a more robust, explicit account of Article 6(7) for AI-facing features—one that advances the DMA’s aims while accommodating security controls. Otherwise, the DMA risks an awkward outcome: interoperability for an AI assistant’s sensory inputs—what appears on a screen or plays through a device’s speakers—would face a weaker legal safety valve than something like sideloading an app.
The legal basis for the Android proceedings lies in Article 6(7) DMA, which requires gatekeepers to:
… allow providers of services and providers of hardware, free of charge, effective interoperability with, and access for the purposes of interoperability to, the same hardware and software features accessed or controlled via the operating system … as are available to services or hardware provided by the gatekeeper.
Article 6(7) also reaches “hardware or software features” not formally part of the operating system if they are “available to, or used by” the gatekeeper in providing services “together with, or in support of” the operating system.