Well-functioning markets are the best tool to stimulate growth and innovation and to reward the hard work that our members put down. These rules are also very important to our members to provide clear guidance in relation to how competition rules will be applied in each of their specific circumstances. Our general opinion is that the market definition at its core still serves its purpose, and that there are no major changes to be requested.
Thereby, the notice is not as much in need of changes as it is of some certain expansions. The existence of zero-price-markets, two-sided-markets and the demarcation between digital and traditional markets should be elaborated upon in the notice. Also, the role of data in relation to market power could be explored, as one way of measuring market power in zero-price-markets. It would also be fruitful with a deeper analysis of the relation to the development on global markets, investment, and merger patterns.