Hat-trick of abuse of dominance: Wolt faces fine for one exclusionary and two exploitative abuses in Danish meal-ordering platform market

Background: Wolt's entry and the complaint

Wolt entered the Danish market in 2017 as a digital meal-ordering platform, connecting consumers with restaurants and other businesses, including through an associated delivery service. 

The case originated in part from a complaint filed by the trade associations Danmarks Restauranter & Caféer (DRC) and HORESTA. The complaint concerned Wolt's contractual terms with restaurants on its platform, including a narrow price parity clause, a promotional discount mechanism, and a term on consumer compensation. On this basis, the DCCA issued a statement of objection to Wolt on 30 January 2024.

The DCCA’s assessment: market definition, dominance and abuse

Relevant market: meal-ordering platforms with delivery

The DCCA defined the relevant product market as the market for meal-ordering platforms with a delivery service, assessed from the perspective of restaurants' demand.

In this regard, the DCCA concluded that meal kits, online grocery stores and similar services do not share sufficient characteristics with meal-ordering platforms to exert meaningful competitive pressure and therefore fall outside the relevant market.

The DCCA’s product market definition is, in this regard, narrower than the European Commission's general approach in comparable cases, as the DCCA's definition excludes restaurants' own sales channels and platforms without delivery.

The relevant geographic market was defined as Denmark. Although local competitive effects may exist, the DCCA found that competitive conditions are sufficiently uniform across the country to justify a national market definition, particularly because Wolt's conduct under investigation did not vary by region.

Wolt argued that it competes internationally with players such as Bolt Food, Uber Eats and Delivery Hero, which could easily enter the Danish market. The DCCA rejected this, noting that the relevant geographic market must reflect areas in which competitive conditions are actually uniform.

Wolt’s dominant position: market shares and market tipping

The DCCA's investigation showed that Wolt held a dominant position in the market for meal-ordering platforms with delivery in Denmark. Its market share rose from 50–60% to 70–80% during the investigated period (2022–2024), giving it by far the largest share – and a growing lead over competitors. Just Eat lost market share and exited the Danish market on 30 April 2026, Foodora exited in June 2024, and Dream Delivery ceased operations in the summer of 2024. The only new entrant is Uber Eats, which entered in 2026.

Moreover, it is of relevance to the assessment of dominance that this market is characterised by strong indirect network effects, i.e. the more restaurants on a platform, the more consumers it attracts, and vice versa. This dynamic makes it increasingly difficult for new or smaller players to compete once one platform achieves critical mass.

The DCCA further concluded that during the investigated period, the Danish meal-ordering platform market had, with a very high probability, either been in the process of tipping in Wolt's favour or may have already tipped. 

Market tipping occurs when a market transitions from genuine multi-player competition to a winner-takes-all scenario in which a single player dominates with only limited competitive pressure. Key elements indicating that market tipping was a genuine risk in this market included the high degree of single-homing on the consumer side (i.e. consumers primarily using only one platform), which reinforced network effects in Wolt's favour, and the inability of existing or potential competitors to shift the competitive landscape during the investigated period.

The three forms of abuse: exclusionary and exploitative conduct

(i) The exclusionary abuse – price parity clause

The DCCA found that Wolt's standard agreements with restaurants included a narrow price parity clause preventing restaurants from undercutting Wolt's prices on their own sales channels, while also giving restaurants a strong incentive not to set lower prices on competing platforms. Although the clause did not formally restrict prices on other platforms (a "broad" price parity clause), the DCCA found it could keep new competitors away from the market and hinder the growth of existing ones, thereby effectively functioning as an exclusionary mechanism.

(ii) The first exploitative abuse – promotional discounts

The DCCA further found that Wolt could unilaterally grant promotional discounts on a restaurant's meals without the restaurant's knowledge or consent. Meanwhile, the price parity clause prevented restaurants from responding by lowering prices on their own sales channels, thereby creating an asymmetry in which only Wolt could influence prices.

(iii) The second exploitative abuse – compensation

The third abuse concerned Wolt's consumer compensation mechanism. If a customer complained about a meal, Wolt could unilaterally pay compensation of up to DKK 400 per order (approximately €50) at the restaurant's expense, regardless of whether the complaint related to food quality or Wolt's own delivery performance. Restaurants had no influence over complaint handling, bore the full financial risk, and – because of the price parity clause – could not pass this risk on through higher prices on the Wolt platform.

Wolt has stated that the standard terms were amended after the DCCA opened the case, and that the price parity clause has not been applied in Denmark since 4 December 2025. The DCCA found that the unlawful conduct had, at the very least, taken place during the period from 1 January 2022 to 31 December 2024, covering a very large number of restaurant agreements.

The DCC’s decision

On the basis of the above findings, the DCC has ordered Wolt to cease the unlawful conduct immediately and to refrain from the same or similar conduct with equivalent effects in the future. Wolt must also inform all restaurants on the platform of the decision and document that this has been done. In addition, the DCC has referred the case to the courts with a view to imposing a fine.

Wolt is expected to challenge the decision, including the finding of dominance. As the DCCA cannot itself impose fines and must refer the matter to the courts, the final outcome will only be determined following court proceedings.

Key takeaways for digital platforms and competition compliance

Narrow price parity clauses may be abusive

For digital platforms with dominant or rapidly growing market shares, the case demonstrates that even narrow price parity clauses, which do not directly prohibit lower prices on competing platforms, can be treated as exclusionary where they effectively prevent business partners from differentiating prices. The DCCA assessed the clause's capability to restrict competition, not its actual effect. Platforms should therefore be aware that standard terms restricting business partners' pricing freedom on their own sales channels may be struck down, even where the clause formally governs only the relationship with the platform itself.

Combining lawful mechanisms with a price parity clause can create exploitative abuse

The case shows that an otherwise lawful commercial mechanism, such as promotional discounts, may become unfair where, combined with a price parity clause, it creates an asymmetry in which only the platform controls competitive parameters such as price. Similarly, an arrangement allowing the platform to unilaterally draw on a business partner's funds without fixed criteria may constitute exploitative abuse where the risk cannot be passed on and the partner is not compensated. Digital platforms should review whether their standard terms grant unilateral, unlimited discretion over business partners' finances or pricing, and whether such terms are necessary and proportionate to a legitimate business objective.

Heightened regulatory scrutiny of digital platform markets

The case underscores – together with the DCC's decision on Uber's acquisition of Dantaxi – that the DCCA has market structure, network effects and the risk of market tipping firmly on its enforcement agenda. Players in multi-sided digital markets should expect continued and intensified regulatory attention to both conduct and structural changes, whether through merger control or abuse of dominance enforcement.

Bird & Bird's article on the Uber case is accessible here.

The DCCA’s press release on the decision is accessible here (in Danish).

The full DCC decision (provisional version) is accessible here (in Danish).

 For more information, please contact Morten Nissen, Alexander Brøchner or Selma Hjorth Aslan