Today, we submitted our formal response to the European Commission’s consultation on the Digital Markets Act (DMA) review. As a small European tech company developing privacy-focused applications like mEUvy, Salary Insights, EUorigin, and EUnify, we felt it was crucial to share our perspective on how these regulations are affecting businesses like ours.
Why We Decided to Speak Up
At vaicat B.V. we’ve built our business around a simple principle: European citizens deserve innovative apps that respect their privacy. Our applications help EU professionals make informed decisions about career moves, understand salary landscapes, and navigate life within the European Union all while keeping their personal data secure.
When the Commission opened its consultation on the DMA’s first-year impact, we saw an opportunity to provide real-world feedback from the SME perspective. Our response reflects months of navigating the new regulatory landscape and its practical implications for small developers.
Our Key Concerns
1. The Hidden Costs of “Open” Markets
While the DMA aims to create fairer competition, it so far has had the opposite effect for us, and we’ve experienced firsthand how it can paradoxically increase costs for small businesses. Our intellectual property protection costs have skyrocketed. What once cost us €100 annually through Apple’s developer program now potentially costs thousands of euros per investigation when dealing with app copies distributed on the web and potentially in alternative marketplaces.
For a small team like ours, this isn’t just a line item it’s a fundamental threat to our ability to protect the innovations we’ve worked hard to create.
2. Privacy Isn’t Just a Feature. It’s Our Foundation!
Our apps handle sensitive personal data: salary information, career aspirations, healthcare data, insurance preferences and location details. We chose to develop for iOS specifically because Apple’s privacy and security features aligned with our values and our users’ expectations.
The DMA’s requirements for third-party access to system features like notifications, WiFi networks, and background processing create new vulnerabilities. When privacy-invasive companies can access the same system-level features we use, they can potentially track and profile our users in ways we cannot prevent. This undermines the very trust our business model depends on.
3. Innovation Tools Being Withheld
Due to the regulatory uncertainty created by the DMA, we’re losing access to cutting-edge development tools. Features like Apple Intelligence and iPhone Mirroring which could significantly accelerate our development process and improve our apps are being withheld from the EU market.
As a small team competing globally, every efficiency matters. When developers in other regions have access to tools we don’t, it puts European innovation at a disadvantage.
(Example) Concretely, iPhone Mirroring could save us a significant amount of engineering time. Considering the sensitivity of the data being handled, Quality Assurance and Testing are of utmost importance to us. Therefore, we conduct rigorous and extended on-device testing across various use cases, edge cases, and other scenarios on multiple devices. The ability to virtually summon an iPhone for on-device testing and switch between them on the same Macs we use for development is crucial to prevent wasting engineering hours on finding the appropriate iPhone to test any specific scenario.
4. Trust Erosion in the Digital Ecosystem
Our user acquisition has relies in a large part on the trust that comes with App Store distribution. Users download our apps knowing they’ve been reviewed, that privacy labels are enforced, and that malicious apps are kept at bay.
With alternative marketplaces and sideloading, this trust is eroding. Even though we distribute exclusively through the App Store, we’re seeing fewer new users willing to experiment with new apps in the EU. The overall platform trust has decreased, affecting all developers not just those using alternative distribution methods.
The Bigger Picture: Europe’s Digital Future
Our concerns extend beyond just our company. The DMA, combined with GDPR, the Data Act, and the AI Act, creates a complex regulatory environment that’s increasingly difficult for small companies to navigate.
Consider these sobering statistics we included in our submission:
- EU startups raised approximately €57 billion in 2023
- US startups raised over €200 billion in the same period
- The UK alone raised approximately €21 billion
This investment gap directly impacts Europe’s ability to build homegrown tech champions. When regulations make it harder for SMEs to compete while potentially benefiting large corporations with resources to navigate complexity, we risk widening this gap further.
Our Recommendations to the Commission
We didn’t just outline problems we offered constructive suggestions:
Create direct communication channels between the Commission and affected small and medium-sized enterprises (SMEs).
Conduct comprehensive security assessments before mandating interoperability features.
Reverse decisions that, in hindsight, prove to be unsafe interventions in security and privacy protocols. Learn from these unsafe interventions to prevent similar incidents in the future.
Consider the cumulative impact of multiple regulations on small businesses.
Provide greater transparency about the experts and research that inform regulatory decisions.
Moving Forward
Despite these challenges, we remain committed to building innovative, privacy-first applications for European users. We’ll continue developing mEUvy, Salary Insights, and our other apps with the same dedication to user privacy and data protection that has always defined us.
We hope our feedback, along with input from other SMEs, will help shape a more balanced approach to digital market regulation one that promotes competition without sacrificing security, encourages innovation without compromising privacy, and creates opportunities for European companies to thrive on the global stage.
The full consultation remains open, and we encourage other SMEs to share their experiences. Only through honest, constructive dialogue can we build a regulatory framework that truly serves European citizens and businesses alike.
vaicat B.V. is a European software company focused on developing privacy-first applications that empower EU citizens with data-driven insights for career and lifestyle decisions. Learn more about our apps at vaicat.com.
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