GAFA – Google, Amazon, Facebook, and Apple – and the inability of ex post enforcement of competition law to prevent potential anticompetitive conduct by these firms. [2] Several European jurisdictions are currently considering an overhaul of their competition policy approach towards dominant companies in the digital economy. A common theme is that competition authorities or newly created digital markets agencies could be given the power to regulate dominant companies with a gatekeeper status. As an important first step in this new regulatory approach, policymakers in various jurisdictions have specified the criteria for identifying the firms, or gatekeepers, that are to be subject to regulation.