Introduction: The DMA and the myth of easy switching The EU’s Digital Markets Act (DMA) (EU, 2022) has been hailed as a landmark in regulating platform monopolies, mandating interoperability and data portability to enhance consumer choice. Apple and Google, the dominant players in mobile ecosystems, publicly frame these provisions as evidence that users can now “switch” platforms without friction, as stated in Google’s official blog on complying with the DMA. Yet, the reality of a full platform migration remains deeply challenging. While basic data such as photos and contacts are transferable, many core layers of users’ digital lives remain tightly locked within their original ecosystems. This “exit penalty” architecture effectively deters migration despite formal compliance with Article 6 of the DMA. Methodology: A real-world migration experiment In early 2026, I conducted a full migration from Apple’s iOS ecosystem to Google’s Android in Japan – a market characterised by dense integration of mobile payments, transit cards (e.g., Suica), and device-dependent identity systems. According to consumer adoption research, by December 2024 more than 40% of respondents in Japan reported using mobile payments as their primary cashless payment method, indicating significant penetration of mobile payment technologies in everyday transactions. According to a Dentsu Cashless Project survey conducted in December 2024, mobile payments had become the most frequently used cashless payment method in Japan. The migration process involved systematically transferring all personal data, communication histories, payment methods, and device-linked services. This empirical approach allowed direct observation of technical, regulatory, and user experience barriers. Detailed logs and verification notes document the step-by-step challenges encountered, highlighting gaps between the DMA’s legal framework and practical exit feasibility. Table 1: The main services migrated, their expected portability under DMA principles, the observed barriers, the required workarounds, and the resulting exit cost types. Category Service / Component Expected portability under DMA principles Observed barrier Required workaround Exit cost type Payments / Transit Suica (Apple Pay) Account/device independence Deregistration requires original iPhone hardware Physical device retention and manual removal Procedural + hardware lock-in Messaging iMessage history Data exportability No meaningful export or full history transfer Archive loss or screenshot/manual saving Data + social lock-in Identity / Security Apple Keychain passwords Structured credential portability CSV export incomplete; 2FA not preserved Manual reconfiguration per account Identity reconstruction cost Devices Apple Watch Cross-platform functionality Core features unavailable on Android Device replacement required Hardware dependency Accounts / Services App-specific logins (multiple) Standardised reauthentication Repeated manual login and verification Individual resets and SMS verification Time + cognitive cost This experiment is informed by established theories of switching costs and platform lock-in in industrial organisation and platform economics, including Paul Klemperer’s Markets with Consumer Switching Costs (1987), Farrell and Klemperer’s Coordination and Lock-In: Competition with Switching Costs and Network Effects (2007), the European Commission report Competition Policy for the Digital Era (2019), and the OECD report Switching Costs and Consumer Policy in Digital Markets (2021). Methodologically, it follows a qualitative case-study approach as outlined in Robert K. Yin’s Case Study Research and Applications (2018), combined with structured migration logs documenting each transfer step, failure point, procedural requirement, and user-side workaround. These observations allow an assessment not only of technical portability, but also of procedural, social, and hardware-based frictions that shape the real cost of exit. Quantitative scope of the migration The migration covered approximately 120 user accounts and digital services across communication, finance, identity management, and hardware ecosystems. The figure refers to accounts and digital services I personally migrated and verified, primarily my own, with several family or administrative accounts managed directly by me. The process was conducted over five consecutive days and involved more than 25 hours of active transfer and verification work. During this process, 34 distinct friction or failure points were documented, including 11 cases requiring manual reconfiguration, 9 cases involving partial or failed data portability, and 6 instances of hardware-dependent constraints. These quantitative observations complement the qualitative logs and provide a structured estimate of the practical costs associated with platform exit. Case study 1: Financial and infrastructural lock-in (Suica and Apple Pay) A prominent example is Japan’s Suica transit card, widely linked to Apple Pay. Despite Apple’s public messaging about portability, deregistering Suica from Apple Pay requires physical access to the original iPhone hardware. This procedural requirement forces users to retain Apple devices as a condition for exit, contradicting the premise of ecosystem independence. This “hardware possession prerequisite” exemplifies how payment and transit infrastructures create layered lock-ins. Such design not only complicates switching but also raises concerns about consumer autonomy and market contestability. Moreover, this barrier is not addressed by the DMA’s current interoperability rules, which primarily focus on data access rather than procedural or device-based constraints. Case study 2: Digital identity, network effects, and social graph barriers Messaging is another critical domain where exit penalties manifest. Apple’s iMessage histories cannot be meaningfully exported or migrated, effectively stranding years of personal communication within Apple’s ecosystem. This loss is not just technical; it entails significant social and economic consequences amplified by strong network effects – where the value of a communication platform grows with the number of users. Many users rely on historical message archives for personal memory, business contacts, and proof of agreements or transactions. The sudden loss or fragmentation of these archives imposes psychological barriers and economic risks, making switching prohibitively costly beyond mere inconvenience. Similarly, passwords and credentials stored in Apple Keychain lack seamless and secure end-to-end export mechanisms. While some basic export functions exist (e.g., CSV), these do not reliably preserve two-factor authentication (2FA) settings or maintain consistent formatting. This forces users into manual, error-prone reconstructions of their digital identities across hundreds of accounts, jeopardising account security and user experience. These frictions highlight how “data portability” in the DMA remains narrowly defined and insufficient in addressing real-world identity migration. According to Article 6 of the EU Digital Markets Act (Regulation (EU) 2022/1925), designated gatekeepers must ensure effective interoperability and data portability sufficient to enable real-world platform switching. Case study 3: Hardware dependencies and sustainability implications Beyond software and data,…
The “exit penalty”: Why the DMA’s interoperability rules fail the reality test of platform migration
