Competition Law and Mapping Platform Concentration Risks

1. Introduction

Platform concentration refers to a situation in which a digital platform, ecosystem, intermediary, or infrastructure provider accumulates substantial economic power over users, business users, data, distribution channels, infrastructure, or adjacent markets.

Traditional competition law often asks whether an undertaking is dominant in a defined relevant market. Platform markets require a broader analysis because competitive power can arise from:

• network effects;
• control over data;
• multi-sided markets;
• switching costs;
• interoperability restrictions;
• vertical integration;
• self-preferencing;
• control over rankings or recommendations;
• access to APIs and essential interfaces;
• ecosystem-wide leveraging;
• acquisitions of nascent competitors; and
• control over multiple layers of the digital supply chain.

The EU's Digital Markets Act illustrates this ecosystem approach: as of 2026, seven gatekeepers—Alphabet, Amazon, Apple, Booking, ByteDance, Meta and Microsoft—cover 23 designated core platform services.

For competition-law analysis, therefore, mapping concentration risk means identifying where economic power sits, how that power is reinforced, and whether it can be transferred from one layer or market to another.

2. Meaning of Platform Concentration

Platform concentration can exist at several levels.

A. User concentration

A platform may control a very large proportion of:

• consumers;
• sellers;
• advertisers;
• developers;
• drivers;
• merchants;
• content creators; or
• enterprise customers.

Large user numbers alone do not necessarily establish unlawful dominance. The legal question is whether concentration creates market power capable of affecting competition.

B. Data concentration

A platform may accumulate:

• search data;
• transaction data;
• behavioural data;
• location data;
• advertising data;
• customer preference data;
• business-user data; and
• cross-platform datasets.

Data concentration can create barriers to entry where rivals cannot obtain comparable datasets or cannot achieve comparable scale.

C. Infrastructure concentration

A platform may control infrastructure such as:

• cloud computing;
• app stores;
• operating systems;
• payment systems;
• logistics networks;
• identity systems;
• APIs;
• advertising exchanges; or
• search infrastructure.

D. Ecosystem concentration

The most significant form is often ecosystem concentration.

For example:

Operating system → app store → payments → advertising → user data → search → cloud → AI services

A firm need not monopolise every individual layer for its ecosystem to create significant competitive leverage.

3. Mapping Platform Concentration

A useful competition-law map can be constructed as follows:

Platform Core
↓
Users + Business Users
↓
Data Collection
↓
Network Effects
↓
Distribution Control
↓
Adjacent Markets
↓
Vertical Integration
↓
Self-Preferencing / Tying / Bundling
↓
Entry Barriers
↓
Reduced Contestability

The objective is to identify whether concentration in one layer creates competitive advantages that cannot readily be replicated by rivals.

4. Relevant Market Definition

The first traditional competition-law question is relevant-market definition.

Platform markets can be:

One-sided

Example:

• online search.

Two-sided

Example:

• marketplace connecting buyers and sellers.

Multi-sided

Example:

• advertising platform connecting consumers, advertisers, publishers and data suppliers.

The relevant market may therefore need to account for interactions between multiple user groups.

A platform can also exercise power in one market while using that power to affect competition in another.

5. Network Effects

Network effects are central to platform concentration.

Direct network effects

The service becomes more valuable as more users join.

Example:

Messaging platform → more users → greater utility → more users.

Indirect network effects

Growth on one side increases value for another side.

Example:

More consumers → more sellers → more product variety → more consumers.

This can produce a self-reinforcing concentration cycle:

Users increase → business users join → data increases → service improves → switching becomes harder → more users join.

Competition law therefore examines whether network effects have become an entry or expansion barrier.

6. Data as a Concentration Mechanism

Data can reinforce platform dominance in several ways.

Data feedback loop

More users
↓
More data
↓
Better algorithms
↓
Better service / targeting
↓
More users
↓
More data

A rival entering the market may therefore face a structural disadvantage.

The competition concern becomes stronger where the platform:

• combines data across services;
• prevents portability;
• restricts access to data;
• uses business-user data against those businesses;
• prevents interoperability; or
• uses exclusive datasets to foreclose competitors.

7. Self-Preferencing

Self-preferencing occurs where a vertically integrated platform gives preferential treatment to its own downstream service.

Examples include:

• ranking its own marketplace products first;
• promoting its own comparison service;
• favouring its own payment system;
• displaying its own advertising services more prominently;
• privileging its own logistics service.

The concern is particularly acute where the platform simultaneously operates the infrastructure and the competing downstream service.

8. Vertical Integration and Leveraging

Platform concentration can create leverage across markets.

For example:

Search dominance
↓
Browser dominance
↓
Operating-system presence
↓
App-store control
↓
Payment control
↓
Advertising data

The legal theory is not simply that the company is large.

The issue is whether market power in one layer is used to restrict competition in another layer.

9. Gatekeeper Power

Modern competition regulation increasingly focuses on gatekeeper characteristics rather than conventional market-share analysis alone.

The EU DMA is an important example. It covers services such as:

• search engines;
• app stores;
• operating systems;
• social networks;
• online intermediation;
• advertising services;
• browsers;
• messaging services; and
• video-sharing platforms. 

This reflects a shift toward examining whether a platform constitutes a gateway through which other businesses must reach users.

10. Platform Concentration and Essential Facilities

A platform may control infrastructure that rivals require.

Examples:

• app-store access;
• operating-system APIs;
• payment interfaces;
• cloud infrastructure;
• marketplace access;
• interoperability interfaces;
• advertising exchanges.

Refusal or discriminatory access may raise issues concerning:

• denial of market access;
• discriminatory conditions;
• exclusionary abuse;
• interoperability;
• essential facilities; and
• foreclosure.

The precise legal test differs between jurisdictions.

11. Six Major Case Laws

Case 1: Google Search / Google Shopping

European Commission – Google Search (Shopping), Case AT.39740

The European Commission found that Google had systematically favoured its own comparison-shopping service in its general search results while demoting competing comparison-shopping services.

Competition significance

The case demonstrates how:

Search-platform power → ranking control → downstream foreclosure

can become a competition concern.

It is particularly relevant to platform-concentration mapping because the platform controlled the gateway through which consumers discovered competing services.

Principle

Control over an important digital gateway can create competitive leverage over adjacent markets.

12. Case 2: Google Android

European Commission – Google Android, Case AT.40099

The European Commission examined Google's contractual arrangements concerning Android devices, including restrictions and incentives associated with Google Search, the Play Store and browser distribution.

The case demonstrates the importance of:

• operating-system control;
• app-store control;
• default settings;
• contractual restrictions;
• distribution agreements; and
• ecosystem leverage.

Competition significance

The relevant concentration map can be expressed as:

Android OS
↓
Play Store
↓
Search
↓
Browser
↓
Defaults
↓
User access

The case therefore illustrates how an operating-system ecosystem can reinforce power across connected markets.

13. Case 3: Google AdSense

European Commission – Google Search (AdSense), Case AT.40411

The Commission examined restrictions imposed on third-party websites concerning the display of search advertisements supplied by competing providers.

Competition significance

The case illustrates intermediation-layer concentration.

A platform can potentially influence competition by controlling access between:

advertisers ↔ publishers ↔ users.

The important lesson is that platform concentration need not arise solely from consumer-facing services. Control over an intermediary layer can itself generate competitive power.

14. Case 4: Amazon Marketplace – CCI

In Re: Allegations pertaining to private label brands related to Amazon sold on Amazon India marketplace, Suo Motu Case No. 04/2021

The Competition Commission of India examined allegations concerning Amazon's marketplace and private-label products.

The case is important because it illustrates a structural conflict potentially arising where a platform acts simultaneously as:

1. marketplace operator;
2. intermediary between sellers and consumers; and
3. participant in product markets.

Competition concern

The platform may possess commercially valuable information concerning:

• seller performance;
• consumer demand;
• pricing;
• product popularity;
• search behaviour; and
• transaction volumes.

That creates a potential platform-as-referee versus platform-as-player problem.

15. Case 5: Google Android TV – CCI

Kshitiz Arya & Purushottam Anand v Google LLC & Others, Case No. 19/2020

The CCI examined allegations concerning Android TV, including bundling of the Play Store with Android TV OS and anti-fragmentation restrictions affecting OEMs.

The matter was subsequently resolved through a settlement approved by the CCI in April 2025.

Competition significance

This demonstrates how ecosystem concentration may extend from:

mobile Android

to:

smart-TV operating systems → app distribution → applications → consumers.

It also illustrates why competition authorities examine contractual restrictions that prevent manufacturers from supporting competing or modified operating-system ecosystems.

16. Case 6: Umar Javeed v Google

Umar Javeed & Others v Google LLC & Another, Case No. 39/2018

The CCI's 2022 proceedings concerned Google's practices in digital markets. The case is part of the development of Indian competition-law analysis of digital ecosystems.

The broader significance is that platform dominance can involve interconnected markets rather than a single isolated product.

Indian competition law under Section 4 of the Competition Act, 2002 provides the principal framework for examining abuse of dominant position.

17. Case 7: Google – Matrimonial / OTT / Digital Media Ecosystems

People Interactive India Pvt. Ltd. & Others v Alphabet Inc. & Others

The CCI considered complaints concerning Google's practices involving matchmaking, audio content and digital-media applications.

Significance

The proceedings illustrate the increasing importance of examining Google's role as a platform that may control multiple digital access points.

The analytical question becomes:

Does control over one digital gateway create an advantage that can be transferred into another market?

That is central to mapping ecosystem concentration.

18. Case 8: Google Play / Anti-Steering – EU

The European Commission has also treated steering restrictions as an important platform-competition issue.

In 2026, the Commission found Google non-compliant with the DMA concerning restrictions on businesses directing users toward alternative purchasing channels through Google Play. It imposed fines of €430 million in relation to the steering issue.

Competition significance

The case illustrates:

App store control → customer relationship → payment channel → transaction fee → downstream competition

A platform can therefore influence competition without completely excluding a rival.

Restrictions on how users and businesses interact outside the platform can themselves affect contestability.

19. Mapping the Main Competition Risks

20. Concentration Across the Platform Stack

A particularly useful methodology is to divide a platform into layers.

Layer 1 – Infrastructure

• cloud;
• servers;
• compute;
• connectivity.

Layer 2 – Operating system

• Android;
• iOS;
• Windows;
• proprietary enterprise systems.

Layer 3 – Distribution

• app stores;
• marketplaces;
• search engines.

Layer 4 – Payments

• wallets;
• payment processors;
• in-app billing.

Layer 5 – Data

• identity;
• transaction;
• behavioural;
• advertising datasets.

Layer 6 – Applications

• social media;
• shopping;
• travel;
• financial services;
• entertainment.

Layer 7 – Advertising

• ad exchanges;
• demand-side platforms;
• publisher services.

The greater the number of layers controlled by the same undertaking, the greater the need to investigate ecosystem leverage and vertical foreclosure.

21. Acquisitions and Platform Concentration

Traditional merger analysis may focus on current market shares.

Digital-platform mergers require additional examination of:

• future competition;
• nascent competitors;
• data accumulation;
• interoperability;
• ecosystem expansion;
• user switching;
• innovation;
• cross-market leverage;
• potential entrants; and
• killer-acquisition theories.

The concern can be expressed as:

Small current competitor + high future competitive potential = potentially significant strategic acquisition.

This is why platform concentration mapping should include corporate acquisition history, not merely present market share.

22. Multi-Homing and Single-Homing

An important indicator is whether users can easily use multiple platforms.

Multi-homing

A seller may use:

• Amazon;
• Flipkart;
• its own website; and
• social-commerce channels.

This can constrain platform power.

Single-homing

If sellers or users effectively depend upon one platform, that platform may acquire greater bargaining power.

Therefore, competition authorities should examine:

• switching costs;
• data portability;
• contractual exclusivity;
• interoperability;
• technical compatibility;
• user identity portability.

23. Switching Costs

Platform concentration becomes more durable when switching is expensive.

Costs may include:

• loss of data;
• loss of followers;
• loss of reputation;
• retraining;
• migration costs;
• incompatible software;
• contractual penalties;
• loss of transaction history;
• loss of accumulated rewards.

Consequently:

High concentration + high switching costs + network effects

can produce substantial barriers to entry and expansion.

24. Interoperability

Interoperability can reduce concentration by allowing competing services to connect with an established platform.

Potential remedies include:

• API access;
• data portability;
• messaging interoperability;
• payment interoperability;
• operating-system interoperability;
• technical standards.

The EU DMA expressly uses interoperability and data portability obligations to improve contestability in areas such as mobile operating systems.

25. Data Portability

Data portability can weaken lock-in.

For example:

Platform A

User data → Platform B

instead of:

Platform A

User data → trapped indefinitely.

However, portability alone may not eliminate network effects if the platform's value derives from relationships and interactions that cannot easily be transferred.

26. Algorithmic Concentration

Platform concentration can also arise through algorithms.

A dominant platform may control:

• search ranking;
• recommendation;
• advertising allocation;
• seller visibility;
• pricing;
• content distribution;
• consumer targeting.

Competition concerns can arise if algorithms systematically:

• favour affiliated businesses;
• disadvantage rivals;
• discriminate against particular sellers;
• facilitate coordination;
• restrict visibility; or
• exploit information asymmetries.

27. AI and Platform Concentration

AI can intensify platform concentration because leading platforms may possess:

• large datasets;
• computing infrastructure;
• foundation models;
• cloud infrastructure;
• distribution channels;
• developer ecosystems;
• proprietary chips;
• consumer interfaces.

This can produce a new concentration chain:

Data → Compute → Model → Platform → Users → More Data

Competition law may therefore need to examine concentration at multiple technological layers simultaneously.

28. Remedies

Possible competition-law remedies include:

Structural remedies

• divestiture;
• separation of business units;
• prohibition of acquisitions.

Behavioural remedies

• non-discrimination;
• prohibition of self-preferencing;
• anti-steering obligations;
• data-access requirements.

Interoperability remedies

• API access;
• technical interoperability;
• messaging interoperability.

Data remedies

• portability;
• data-sharing arrangements;
• restrictions on combining datasets.

Transparency remedies

• ranking transparency;
• advertising transparency;
• access-condition transparency.

The appropriate remedy depends on the precise theory of harm and jurisdiction.

29. A Practical Platform Concentration-Risk Matrix

30. Indian Legal Framework

The principal Indian framework is the Competition Act, 2002.

Platform concentration can engage:

Section 3

Anti-competitive agreements, including:

• vertical restraints;
• exclusive arrangements;
• tying;
• refusal to deal;
• resale restrictions.

Section 4

Abuse of dominant position, including:

• unfair or discriminatory conditions;
• unfair pricing;
• limiting production or technical development;
• denial of market access;
• tying;
• leveraging dominance into another market.

Sections 5 and 6

Regulation of combinations, including mergers and acquisitions capable of affecting competition.

The CCI's increasing body of digital-platform cases demonstrates the application of these provisions to ecosystem-based markets.

31. EU Legal Framework

The EU approach combines:

Article 102 TFEU

Abuse of dominant position.

Articles 101 TFEU

Anti-competitive agreements and concerted practices.

EU Merger Regulation

Concentration control.

Digital Markets Act

Ex ante obligations for designated gatekeepers.

The DMA is particularly important because it supplements traditional ex post competition law with ex ante obligations aimed at contestability and fairness.

32. Key Legal Issues in Mapping Platform Concentration

The principal questions for a competition authority are:

1. Who controls the gateway?
2. Who controls the data?
3. Who controls distribution?
4. Who controls the ranking algorithm?
5. Can business users realistically switch?
6. Can users multi-home?
7. Are APIs accessible?
8. Does the platform compete with its own business users?
9. Does it combine data across markets?
10. Does it favour its own services?
11. Does it impose tying or bundling?
12. Does it restrict steering?
13. Does it acquire emerging competitors?
14. Can market power be transferred into adjacent markets?
15. Would interoperability or portability materially reduce the concentration?

33. Emerging Concept: Ecosystem Dominance

The traditional model is:

One market → one dominant firm → one theory of harm

The digital-platform model increasingly requires:

Multiple connected markets → common infrastructure → common data → common users → ecosystem leverage.

This does not mean that ecosystem size automatically establishes an infringement. Rather, it changes where the competition authority should look for evidence of market power and foreclosure.

34. Conclusion

Mapping platform concentration risks requires competition law to move beyond simple market-share analysis and examine the architecture through which platform power is created and maintained.

The most important variables are:

Network effects + data concentration + switching costs + interoperability + vertical integration + gateway control + self-preferencing + ecosystem expansion + acquisitions.

The major Google, Amazon and Android cases demonstrate that competition concerns can arise at different points of the platform stack. Recent EU gatekeeper regulation and Indian CCI digital-market enforcement further demonstrate the growing importance of analysing platform ecosystems rather than isolated digital products.