The EU Digital Markets Act: What It Means for Affiliate and Commerce Media in 2026

The EU's Digital Markets Act has been reshaping digital advertising since 2023, and by 2026 its effects on performance marketing are impossible to ignore. Most brands are still treating it as a legal problem. It's actually a strategic one.

The DMA designates certain large platforms — Google, Meta, Apple, Amazon, Microsoft, TikTok — as "gatekeepers" and imposes specific obligations on how they can collect, combine, and use data across their services. For affiliate marketers and commerce media buyers, the downstream effects are significant. Consent rates on Meta in the EU have dropped. Cross-platform audience matching has gotten harder. Attribution signals are more fragmented than ever. And yet many brands are still running their EU campaigns as if nothing changed.

Here's what's actually happening — and what to do about it.

What the DMA Actually Requires of Gatekeepers

The DMA requires designated gatekeepers to, among other things, obtain explicit consent before combining personal data across different services, give users the ability to opt out of personalized advertising, and provide advertisers with access to their own campaign performance data without tying it to proprietary measurement tools.

In practice, this means:

• Meta's EU users face consent screens before seeing personalized ads — estimates put EU opt-out rates at 40–60% depending on country and context.
• Google's audience targeting in the EU is constrained; cross-service data combination (YouTube + Search + Gmail) requires granular consent that a significant portion of users decline.
• Amazon's sponsored products and DSP targeting are similarly affected for EU shoppers, compressing the audience pools performance marketers relied on.

For performance marketers, these aren't abstract compliance details. They're erosions in the signal quality that campaign optimization algorithms depend on — and they show up directly in reported ROAS and conversion volume.

How DMA Changes the Data Equation for Affiliate Marketers

Affiliate marketing is, by design, less reliant on platform-level behavioral data than paid social. A content publisher recommending a product doesn't need Meta's pixel to drive a click. But the DMA still bites in ways that catch affiliate managers off guard.

Attribution is the most immediate issue. Many affiliate platforms — particularly those integrated with Meta's Conversions API or Google's enhanced conversions — rely on cross-platform signals to match affiliate clicks to purchases. When those signals get noisier in the EU, last-click attribution windows become less reliable, and networks may undercount EU conversions by a meaningful margin.

The brands that will navigate DMA best aren't the ones who hired the most compliance lawyers. They're the ones who built enough first-party data infrastructure that they don't depend on gatekeeper signals in the first place.

This isn't a reason to panic — it's a reason to reassess how you're measuring affiliate performance in EU markets. First-party server-side tracking, integration with affiliate networks that support cookieless attribution (TradeTracker and Tradedoubler have both invested significantly here), and clear baseline conversion metrics are the practical response.

The Commerce Media Opportunity Hidden in Gatekeeper Restrictions

Here's the contrarian take: the DMA is genuinely good news for commerce media on the open web.

When Meta's targeting efficiency drops in the EU, the relative value of high-intent contextual placements — product comparison sites, editorial reviews, affiliate content — goes up. Publishers with strong first-party audience relationships and clear purchase-intent signals are exactly what performance-minded advertisers need when walled garden data dries up. You don't need behavioral surveillance to reach someone who just searched "best running shoes under €150."

Platforms like Taboola and Yahoo DSP, which operate primarily outside the walled gardens on contextual signals, have been gaining ground in EU markets precisely because they're structurally less affected by DMA constraints. DV360's programmatic open web inventory is similarly positioned. If you've been over-indexed on Meta for EU performance, the DMA is a push toward channel diversification you probably should have already made.

What to Do Now: A Practical Checklist

If you're running affiliate or commerce media campaigns in the EU, here's where to focus:

• Audit your EU attribution setup. Pixel-based tracking is being systematically degraded by consent requirements. Server-side solutions are table stakes now, not a future project.
• Check your affiliate network's cookieless tracking options. Networks like Tradedoubler and TradeTracker have EU-native infrastructure. Know what your fallback is for non-consented users before a compliance audit forces the question.
• Build EU-specific incrementality baselines. EU conversion rates and attribution behavior are now structurally different from US or APAC markets. Treating them as one measurement problem will give you wrong answers for both.
• Diversify your EU media mix toward contextual placements. High-intent editorial and affiliate content becomes relatively more valuable when behavioral targeting is constrained — and the CPMs often haven't caught up yet.
• Document your consent and data flows. Not just for legal protection, but because you'll need this to accurately interpret performance swings when consent rates shift.

The EU Digital Markets Act is forcing the performance marketing industry to figure out how to drive measurable revenue without depending on surveillance-grade behavioral signals. That's uncomfortable in the short term. In the long term, it's the right forcing function. Real incremental revenue — the kind that doesn't evaporate when a platform changes its targeting algorithm — was never built on borrowed data anyway. The brands building first-party infrastructure, diversifying into high-intent contextual channels, and measuring EU performance on its own terms will come out ahead. The ones waiting for the DMA to go away won't.