Terms of reference: Testing DMA gatekeeper user interfaces for neutrality

The Bureau Européen des Unions de Consommateurs (BEUC) is spearheading an initiative to scrutinize the user interface designs of designated gatekeepers under the Digital Markets Act (DMA). This effort aims to ensure these major digital platforms comply with the DMA's mandate for fair competition and consumer choice, particularly concerning data usage consent. The initiative underscores the EU's commitment to rebalancing power in digital markets and safeguarding end-user autonomy. This research will specifically test whether gatekeeper interfaces are employing subtle "steerage" techniques, potentially violating DMA articles that prohibit non-neutral choices and undermining free decision-making. The methodology will involve analyzing interfaces from at least two gatekeepers across representative samples from three European countries. This detailed examination is crucial for identifying potential breaches of the DMA's strictures against manipulative design practices. The findings will directly impact how large digital platforms interact with consumers regarding data consent and service usage. By ensuring interface neutrality, the DMA seeks to protect users from being unduly influenced towards choices that benefit the gatekeepers, thereby fostering a more transparent and equitable digital environment. This testing phase is a critical step in enforcing the DMA's objective of promoting genuine contestability and consumer welfare in the digital sphere.