Digital Ecosystem Mapping as an Enforcement Methodology in Competition Law

1. Introduction

Digital ecosystem mapping is an enforcement methodology used by competition authorities to understand how a digital platform exercises market power across interconnected products, services, data flows, infrastructure, algorithms, users, suppliers, and complementary markets.

Traditional competition analysis often examines a single relevant market and asks whether a firm possesses substantial market power within that market. Digital ecosystems complicate this approach because a dominant undertaking may exercise influence through a network of interconnected markets, even where no individual component market completely explains its competitive position.

Ecosystem mapping therefore seeks to identify:

• the central platform or ecosystem orchestrator;
• participating users and business users;
• complementary products and services;
• data flows;
• APIs and interoperability arrangements;
• operating systems and technical infrastructure;
• distribution channels;
• switching costs;
• network effects;
• algorithmic dependencies;
• contractual restrictions;
• self-preferencing mechanisms;
• vertical and conglomerate relationships;
• acquisition pathways; and
• potential foreclosure points.

The methodology is particularly relevant to digital-platform investigations, abuse of dominance, exclusionary conduct, mergers, interoperability disputes, data-access cases and algorithmic competition concerns.

2. Meaning of Digital Ecosystem Mapping

A digital ecosystem can be represented as:

Core platform → users → complementary services → data → infrastructure → distribution → adjacent markets → feedback effects

The important insight is that competitive power may arise not merely from the platform's share in one market but from its control over connections between markets.

For example, a technology company might simultaneously operate:

operating system + app store + payment service + browser + advertising platform + cloud infrastructure + identity system + data analytics.

Each component can reinforce the others.

Ecosystem mapping therefore asks five fundamental questions:

1. Who controls the ecosystem?
2. Which participants depend upon that control?
3. What resources or interfaces connect the ecosystem's markets?
4. Where can exclusion or discrimination occur?
5. How does conduct in one market affect competition elsewhere?

3. Why Mapping Is Necessary in Digital Markets

A. Digital markets are interconnected

A conventional market definition may isolate:

online search

But competitive analysis may require examination of connections among:

• search;
• browsers;
• mobile operating systems;
• advertising;
• user data;
• default settings;
• app distribution; and
• device manufacturers.

The ecosystem map reveals competitive relationships that may disappear when markets are analysed separately.

B. Market power may be distributed across layers

Digital ecosystems generally have several layers:

Infrastructure layer

Cloud computing, data centres, chips and connectivity.

Platform layer

Operating systems, app stores, marketplaces and social networks.

Service layer

Search, payments, advertising, communications and productivity applications.

Data layer

Identity, behavioural data, transaction information and analytics.

Interface layer

APIs, SDKs, search defaults and interoperability mechanisms.

User layer

Consumers, developers, advertisers, merchants and other business users.

Competition authorities can therefore investigate control over an ecosystem bottleneck, rather than simply looking at market share.

4. Digital Ecosystem Mapping as an Enforcement Tool

The methodology can be divided into eight enforcement stages.

Stage 1 — Identify the ecosystem's core

The authority identifies the undertaking around which the ecosystem is organised.

Relevant indicators include:

• user numbers;
• developer dependence;
• network effects;
• data advantages;
• technological standards;
• distribution control;
• contractual relationships;
• interoperability;
• default status; and
• switching costs.

The central undertaking need not possess monopoly power in every connected market.

Stage 2 — Map participants

Authorities should identify:

This creates a dependency map.

5. Dependency Mapping

One of the most useful features of ecosystem mapping is identifying economic dependency.

A platform may not explicitly prohibit competitors from entering.

Instead, competitors may face:

high switching costs + lack of data + restricted APIs + poor interoperability + distribution disadvantages.

The combined effect may substantially impair competition.

Example

Suppose Platform A controls:

OS → app store → payment system → identity system → advertising → analytics

A competing payment provider may technically be permitted to enter.

But if Platform A:

• controls app distribution;
• restricts payment APIs;
• gives its own service privileged access;
• controls authentication;
• collects superior transaction data;

the competitor may remain commercially dependent on Platform A.

Mapping makes this chain visible.

6. Data-Flow Mapping

Data is frequently the connective tissue of digital ecosystems.

An enforcement map should therefore trace:

Data generation → collection → processing → storage → analytics → monetisation → feedback

For example:

consumer activity → platform collection → behavioural profile → advertising optimisation → increased revenue → improved service → additional users → additional data.

This creates a data-network feedback loop.

The authority can then investigate whether rivals can obtain comparable data or whether the incumbent's data advantages constitute an exclusionary mechanism.

7. Interface and Bottleneck Mapping

Digital ecosystems often depend upon technical interfaces.

Examples include:

• APIs;
• SDKs;
• operating systems;
• app stores;
• identity systems;
• payment interfaces;
• search defaults;
• cloud interfaces;
• interoperability protocols.

An authority should identify:

Who controls the interface?

and

What happens if access is restricted?

This can reveal an essential interface or strategic bottleneck.

8. Algorithmic Mapping

Modern ecosystems increasingly rely on algorithms.

Authorities may map:

• ranking algorithms;
• recommendation systems;
• pricing algorithms;
• advertising auctions;
• search results;
• content moderation;
• matching systems;
• fraud detection;
• eligibility algorithms.

The central question becomes:

Does the ecosystem operator use algorithmic control to favour its own products or disadvantage dependent rivals?

This makes ecosystem mapping particularly relevant to self-preferencing, discriminatory ranking, algorithmic exclusion and platform neutrality investigations.

9. Transaction and Acquisition Mapping

Ecosystem mapping is also useful in merger enforcement.

Authorities can map:

Core platform → emerging competitor → complementary technology → data → users → future competitive constraint

This is important where an acquisition target has relatively small current revenues but significant future ecosystem significance.

The authority may investigate:

• nascent competition;
• potential competition;
• data assets;
• interoperability;
• user migration;
• innovation;
• complementary technologies;
• vertical integration; and
• elimination of a future ecosystem challenger.

10. Six Major Case Laws

1. Google Search (Shopping) — European Union

Google Search (Shopping), Google and Alphabet v European Commission, Case C-48/22 P

This litigation concerns Google's conduct in favouring its own comparison-shopping service within general search results.

Relevance to ecosystem mapping

The case demonstrates why enforcement cannot necessarily stop at asking whether Google operates a search engine.

The competitive investigation involves the relationship between:

general search → ranking → traffic → comparison-shopping services → advertisers → user data.

Google's control over search visibility could affect competition in an adjacent comparison-shopping market.

Enforcement lesson

Ecosystem mapping helps authorities identify how control over a gateway market can influence competition in connected markets.

The case is therefore highly relevant to:

• self-preferencing;
• ranking;
• traffic diversion;
• platform neutrality; and
• leveraging.

2. Google Android — European Union

Google Android, Google and Alphabet v European Commission, Case C-738/20 P

The Android litigation concerned Google's conduct involving mobile operating systems, app stores, search services and contractual arrangements.

Ecosystem structure

The relevant ecosystem can be represented as:

Android OS → Google Play → applications → Google Search → mobile users → advertising/data.

The case illustrates the importance of examining several interconnected contractual and technological relationships.

Enforcement lesson

A digital ecosystem may allow an undertaking to use control at one layer to reinforce its position at another.

Consequently, enforcement authorities should map:

• operating-system control;
• app distribution;
• defaults;
• contractual restrictions;
• search;
• device manufacturers; and
• user behaviour.

3. Google AdSense — European Union

Google and Alphabet v European Commission, Case C-233/16 P

The AdSense case concerned Google's conduct relating to search advertising intermediation.

Ecosystem relevance

The advertising ecosystem may be mapped as:

advertiser → advertising intermediary → publisher → search/display environment → users → data → advertising optimisation.

Google's position in multiple layers of the advertising chain illustrates how vertical integration can create opportunities for foreclosure.

Enforcement lesson

Ecosystem mapping allows authorities to examine whether a firm can leverage power from one part of a digital value chain into another.

4. Microsoft — European Union

Microsoft Corp. v Commission, Case T-201/04

The Microsoft litigation concerning interoperability and tying remains one of the most important precedents for analysing digital platform ecosystems.

Microsoft's Windows ecosystem connected:

operating system → applications → interoperability protocols → servers → software developers → users.

The interoperability issue demonstrated how control over a technological platform can affect neighbouring markets.

Enforcement lesson

A platform's competitive significance cannot always be understood from the platform market alone.

The authority must identify:

• technological dependencies;
• interoperability barriers;
• network effects;
• developer dependence; and
• leveraging opportunities.

5. Apple App Store — European Union

Apple Inc. v European Commission, Case T-1079/23

The broader Apple App Store enforcement context illustrates the significance of ecosystem mapping in examining the relationship between:

iOS → App Store → developers → payment systems → consumers → commissions → alternative distribution.

The investigation of Apple's platform arrangements demonstrates how competition issues may arise from the interaction of several layers rather than from a single isolated product.

Enforcement lesson

A platform operator can occupy several positions simultaneously:

• infrastructure provider;
• distributor;
• marketplace operator;
• payment intermediary; and
• rule-maker.

Ecosystem mapping makes those overlapping roles visible.

6. United States v. Google — Search and Advertising Ecosystem

The U.S. antitrust litigation involving Google provides an important illustration of ecosystem-oriented enforcement.

The search ecosystem involves:

users → browsers/devices → search access points → search engine → queries/data → advertising → revenue → investment in search quality.

The advertising ecosystem similarly connects:

advertisers → ad technology → publishers → users → data → auctions → advertising revenue.

Enforcement lesson

The case demonstrates why authorities may examine distribution channels and commercial agreements surrounding a core platform, rather than examining the search engine as an isolated technological product.

11. Additional Important Authorities

Although six cases satisfy the minimum requirement, several other authorities are highly relevant.

United States v Microsoft Corp.

The Microsoft litigation established important principles concerning technological platforms, exclusionary conduct, browser distribution and network effects.

Qualcomm — European Union

The Qualcomm litigation illustrates the importance of analysing vertical relationships, technological standards and exclusionary incentives in complex technology markets.

Intel — European Union

The Intel litigation demonstrates how competition authorities may analyse conditional rebates and their effects within technologically complex markets.

Meta Platforms / Bundeskartellamt

The German Facebook/Meta proceedings are particularly significant because they connect:

platform dominance → data collection → terms of service → privacy/data practices → competitive dependence.

This demonstrates the growing importance of cross-regulatory ecosystem mapping.

12. Ecosystem Mapping and Relevant Market Definition

Ecosystem mapping does not eliminate the relevant-market requirement.

Instead, it supplements it.

A competition authority may use a sequence such as:

Step 1

Define individual relevant markets.

Step 2

Identify relationships between those markets.

Step 3

Map the ecosystem connecting them.

Step 4

Identify the firm's control points.

Step 5

Determine whether conduct in one market affects competition in another.

Step 6

Analyse actual or potential foreclosure.

This avoids treating "ecosystem" as a substitute for legally established market analysis.

13. Ecosystem Mapping and Abuse of Dominance

Mapping can assist in identifying several forms of abuse.

A. Self-preferencing

Platform → ranking → own product

The platform may use control over visibility to favour its own service.

B. Tying

Dominant product → compulsory complementary product

The ecosystem operator uses strength in one layer to expand another service.

C. Exclusive dealing

Platform → contractual restrictions → reduced rival access

D. Refusal of interoperability

Platform → technical interface → competitor exclusion

E. Discriminatory access

Platform → unequal technical/commercial conditions → rival disadvantage

F. Data leveraging

Core service → superior data → adjacent market advantage

G. Predatory or strategic pricing

The platform may use ecosystem-wide revenue streams to sustain aggressive pricing in a particular market.

14. Ecosystem Mapping and Network Effects

Network effects should be mapped explicitly.

There are generally two categories.

Direct network effects

More users make the platform more valuable to other users.

Users ↑ → platform value ↑ → users ↑

Indirect network effects

More users attract complementary suppliers.

Users ↑ → developers ↑ → applications ↑ → platform attractiveness ↑ → users ↑

This creates a reinforcing loop.

A dominant ecosystem can therefore become difficult to challenge even without conventional exclusive contracts.

15. Ecosystem Gravity

A particularly important enforcement concept is ecosystem gravity.

The larger the ecosystem becomes, the more activities may naturally remain within it.

For example:

identity → payments → applications → communications → storage → advertising → commerce.

Users may remain because leaving one service requires leaving several interconnected services.

This creates multi-product switching costs.

An enforcement authority should therefore examine whether the ecosystem's integration creates:

• technical lock-in;
• data lock-in;
• contractual lock-in;
• financial lock-in;
• social lock-in; or
• behavioural lock-in.

16. Mapping Competitive Bottlenecks

A useful enforcement map identifies critical bottlenecks.

The authority can then prioritise the bottlenecks capable of producing the greatest competitive harm.

17. Ecosystem Mapping and Remedies

Mapping is not merely an investigative device. It can also inform remedies.

Structural remedies

Where ecosystem power is entrenched, authorities may consider:

• divestiture;
• separation of business units;
• limits on vertical integration.

Behavioural remedies

Mapping can support:

• interoperability obligations;
• non-discrimination;
• data portability;
• API access;
• transparency;
• default-choice mechanisms;
• restrictions on self-preferencing.

Governance remedies

Authorities may also require:

• independent compliance monitoring;
• algorithmic auditing;
• internal information barriers;
• reporting obligations;
• access-monitoring mechanisms.

18. Digital Ecosystem Mapping vs Traditional Market Analysis

The methodologies should not be viewed as mutually exclusive.

Ecosystem mapping is an additional analytical layer.

19. Proposed Enforcement Framework

A competition authority could operationalise ecosystem mapping through the following framework:

Phase I — Discovery

Identify:

• ecosystem owner;
• core products;
• complementary products;
• users;
• competitors;
• suppliers.

Phase II — Dependency analysis

Identify:

• switching costs;
• contractual dependence;
• data dependence;
• technical dependence;
• distribution dependence.

Phase III — Control-point analysis

Identify:

• APIs;
• operating systems;
• app stores;
• defaults;
• rankings;
• payments;
• identity systems.

Phase IV — Conduct mapping

Trace:

conduct → affected participant → affected layer → adjacent market → competitive effect.

Phase V — Feedback analysis

Determine whether the conduct creates:

exclusion → greater concentration → more users/data → greater market power → further exclusion.

Phase VI — Remedy mapping

Identify the minimum intervention necessary to restore contestability.

20. Limitations of Ecosystem Mapping

Ecosystem mapping also presents legal risks.

A. Risk of excessive breadth

Calling every connected service part of one "ecosystem" can make the relevant market concept meaningless.

B. Risk of speculative causation

Connection between two markets does not automatically establish anticompetitive effects.

C. Risk of confusing size with dominance

A large ecosystem is not necessarily an anticompetitive ecosystem.

D. Risk of innovation penalties

Integration may generate legitimate efficiencies.

E. Risk of regulatory overlap

Competition authorities may encounter privacy, consumer-protection, intellectual-property and sectoral regulation simultaneously.

Therefore, mapping should be followed by rigorous analysis of:

dominance → conduct → effects → causation → efficiencies → remedy.

21. Core Legal Principle

The strongest legal formulation is:

Digital ecosystem mapping should be treated as an evidentiary and analytical methodology, not as an independent theory of liability.

An authority still has to establish the statutory elements of the relevant competition-law infringement.

The map helps demonstrate how market power travels through an interconnected digital structure.

22. Conclusion

Digital ecosystem mapping represents an important evolution in competition-law enforcement.

Traditional analysis tends to ask:

"What is the relevant market and how powerful is the undertaking within it?"

Ecosystem enforcement adds:

"How is economic power distributed across the interconnected digital system, where are the bottlenecks, who depends upon them, and how can conduct in one layer affect competition elsewhere?"

The Google Shopping, Google Android, Google AdSense, Microsoft, Apple App Store and Google U.S. antitrust proceedings collectively illustrate why digital enforcement increasingly requires attention to platform gateways, interoperability, defaults, distribution, data, algorithms, vertical relationships and adjacent markets.

Accordingly, digital ecosystem mapping can be conceptualised as:

Market definition → ecosystem identification → dependency mapping → data/interface mapping → bottleneck identification → conduct mapping → foreclosure analysis → feedback effects → remedy design.