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Integrated Intermediation,Indirect Ecosystem Capture, and theCase for Cloud Neutrality Antonio Manganelli EuropeanDataSummit2026 Gatekeepersin the Cloud Integrated Intermediation,Indirect Ecosystem Capture, and theCase for Cloud Neutrality At a Glance Despite cloud computing services being listed as a core platform serviceunder the Digital Markets Act, no hyperscaler has been designated asa gatekeeper. This paper argues that the persistent failure of designa-tion reflects a structural incompatibility between the DMA’s two-sidedplatform logic and the vertical pipeline architecture of cloud markets –amismatch that renders both the quantitative thresholds and the qual-itative gateway criterion analytically ill-suited to the cloud context. Thepaper, however, proposes two paths to qualitative designation underArticle 3(8): an “integrated intermediation” framework grounded in thetwo-sided economics of cloud and AI marketplaces, and an “indirectecosystem capture” framework that extends the relevant end-user anal-ysis to those drawn into hyperscaler ecosystems through downstreamservice consumption. Conditional on designation, it develops a remedialframework centred on “cloud neutrality” under Article 6(6), data obli-gations under Articles 6(2) and 6(9), and the application of Article 5(7)’santi-tying obligation to hyperscaler identity and access managementsystems. The analysis engages directly with the European Commission’sNovember 2025 dual-track investigations into AWS and Microsoft Azure. Table of Contents 6—Preface8—1. Introduction: Concentrated CloudMarkets and the Limits of Antitrust11—2. Gatekeeper Designation112.1 Cloud Services and the DMA:ThePlatform- Pipeline Mismatch162.2 Possible Paths to Designation21—3. Applicable Remedies213.1 A Case for “Cloud Neutrality”273.2. Further Applicable Obligations: Data,Intermediation Fairness, and IdentityManagement33—4. Conclusions38—The Author Preface Cloud computing is crucial to Europe, not only as a technology sector butas the foundation of the data economy. It underpins nearly every sectorand enables leadership in emerging technologies such as AI. Yet Europe’scloud market is dominated by a small number of very large overseashyperscalers. Structural barriers, including market fragmentation, lim-ited access to capital, and unintended consequences of EU regulation,prevent many European cloud providers, particularly SMEs, from fullycompeting. In recent years, the Konrad-Adenauer-Stiftung has played an active rolein addressing regulatory gaps and enforcement challenges related todigital gatekeepers. The underlying study by Antonio Manganelli repre-sents our timely contribution to identifying workable solutions within theexisting regulatory framework, namely the Digital Markets Act (DMA).The DMA was designed as a complement to competition law and aimsto address structural market failures in the digital economy through exante regulation. Despite cloud computing services being explicitly listedas a core platform service, the regulation has remained largely inopera-tive in this sector. This regulatory gap was formally acknowledged in November 2025, coin-ciding with the Digital Sovereignty Summit in Berlin, when the EuropeanCommission launched three market investigations. While these stepsmark progress, they also reveal deeper structural tensions in applyingthe DMA to cloud markets. At its core, the DMA is built around the economic model of the two-sidedplatform. Cloud computing, however, operates according to a fundamen-tally different logic, as this study clearly illustrates. Cloud services areorganised as vertically integrated value chains, with infrastructure serv-ing as an upstream input for downstream digital services. Antonio Manganelli identifies concrete analytical shortcomings under-lying this outcome and proposes corrective pathways that could con-tribute to a more contestable cloud economy in the European Union.The study outlines a remedial framework, conditional on gatekeeperdesignation, structured around complementary regulatory approaches,including data-related obligations, marketplace fairness rules, and, mostnotably, the principle of cloud neutrality. Understanding where intermediation actually occurs, most prominentlyin cloud marketplaces, and addressing deeper forms of lock-in, includ-ing identity management systems, is essential to ensuring that the DMAachieves its objective of safeguarding fairness and contestability in theevolving digital economy. As Manganelli highlights, applying the DMA tocloud markets will require not only rigorous enforcement but also con-ceptual adaptation. Without a competitive cloud sector, the European Union cannot achieveits objectives of digital sovereignty. With this publication, released onthe occasion of the European Data Summit in Berlin, we aim to providemeaningful support to the work of the European Commission and otherenforcement authorities across Europe. Pencho KuzevKonrad-Adenauer-Stiftung e. V. 1