Amazon’s European Reach: Analyzing the Shift in Digital Engagement Under the DSA

In the evolving landscape of European e-commerce, Amazon remains a colossal presence, yet recent data reveals a nuanced shift in its user base. According to the latest transparency filings submitted to the European Commission, Amazon’s reach—measured as the Average Monthly Active Recipients (AMARs)—within the European Union has experienced a modest contraction. This cooling of engagement serves as a critical indicator of market saturation and the shifting competitive dynamics of the digital single market.

Main Facts: A Slight Contraction in European Engagement

Amazon reported an average of 193.9 million monthly active recipients across the European Union for the first half of this year. This figure represents a slight decline from the 195.2 million reported in the second half of the previous year.

It is essential to clarify the metric: these AMARs represent individuals who have interacted with Amazon’s services within the EU, a classification that extends beyond mere transactional buyers to include casual browsers, users of Amazon-hosted services, and those interacting with the platform’s various digital ecosystems. While the numbers suggest a marginal retreat, the scale remains massive, underscoring Amazon’s entrenched position in the daily digital habits of millions of Europeans.

The data, provided as part of mandatory compliance with the Digital Services Act (DSA), offers a rare, granular look at how Amazon is performing in specific member states. While the aggregate EU figures paint a picture of stagnation, the underlying country-by-country data reveals a stark contrast between established, mature markets and emerging, high-growth territories.

Chronology: The Digital Services Act and Transparency Reporting

To understand these figures, one must look at the regulatory framework that necessitates their publication. Since 2023, Amazon has been required to submit regular transparency reports to the European Commission under the Digital Services Act (DSA). The DSA, designed to regulate digital platforms and ensure a safer, more transparent online environment, requires "Very Large Online Platforms" (VLOPs) to disclose the number of their active recipients periodically.

The Evolution of Reporting

Last year, the European Commission harmonized the reporting requirements for all major digital players. This synchronization was a watershed moment for market analysts, as it finally allowed for an "apples-to-apples" comparison of user data. Before this harmonization, fragmented reporting standards made it difficult to track longitudinal growth or decline accurately. Now, with the two most recent reporting periods (H2 2025 and H1 2026) aligned, we can begin to see the true trajectory of Amazon’s European footprint.

Supporting Data: Regional Divergence and Market Dynamics

Amazon’s dominance is heavily concentrated in its core markets, yet these are precisely the areas showing the most significant signs of cooling.

The Core Four: Germany, France, Italy, and Spain

Germany remains the undisputed heart of Amazon’s European operations. With 52.8 million monthly active recipients, it continues to dwarf all other EU member states. However, this market is also seeing a decline of 1.7%, suggesting that Amazon has reached a level of penetration where growth is increasingly difficult to sustain against existing retail competition and local economic headwinds.

France and Italy follow, with 38.8 million and 38.1 million active recipients respectively. France recorded a 4.0% decline, marking the most significant drop among the top five markets. Italy, conversely, remained relatively stable with a minor dip of 0.1%. Spain, reporting 27.9 million recipients, saw a 1.0% contraction.

The Dutch Exception

The Netherlands presents a fascinating anomaly. As the smallest of the top five markets mentioned, it is the only one to register growth, with active recipients rising by 4.0% to reach 6.6 million. This growth is largely attributed to Amazon’s aggressive, ongoing investment strategy in the region.

Having introduced a dedicated Dutch store more recently than its neighbors, Amazon is still in a phase of aggressive market acquisition. The company is currently executing a 1.4 billion euro, three-year investment plan aimed specifically at closing the gap with Bol, the incumbent Dutch market leader. Despite this, data from the ECDB shows that while Amazon’s sales in the Netherlands grew by 2.7% last year, the competitive gap with Bol actually widened, demonstrating that "reach" does not always equate to immediate market share dominance.

Growth Outliers: Denmark and the Nordic Expansion

While the "Big Five" markets show signs of maturation, the most dramatic growth is occurring in smaller, perhaps underserved, territories. Denmark leads the EU in growth, with a staggering 18.4% increase in AMARs. Sweden (+13.9%) and Ireland (+12.1%) also posted double-digit growth. This suggests that Amazon’s strategy of leveraging its existing logistics network to push into Northern and Western European peripheries is yielding significant fruit.

Conversely, the sharpest decline was recorded in Greece, where Amazon saw a 20.2% drop in active recipients. In Greece, local player Skroutz maintains a ironclad grip on the market, illustrating the resilience of localized platforms against global behemoths.

Official Responses and Strategic Implications

Amazon has maintained a relatively low profile regarding the interpretation of these figures, focusing instead on its role as a compliant partner to the European Commission. Their transparency reports are positioned as a commitment to the "Trustworthy Shopping" initiative, which aligns with the broader DSA goals of fostering consumer trust.

Competitive Strategy

The implication of these findings is that Amazon is entering a "post-growth" phase in its largest markets. In Germany and France, the focus is likely shifting from pure user acquisition to increasing the lifetime value of existing customers through Prime subscriptions, cloud service integration, and advertising.

The contrast between the decline in mature markets and the growth in regions like Denmark suggests that Amazon is reallocating its focus. The company is betting on the fact that while it cannot easily convert the remaining 10% of the population in Germany, it can rapidly scale its logistics and service offerings in smaller nations where e-commerce infrastructure is still evolving.

The Regulatory Landscape

The DSA transparency requirements act as a double-edged sword for Amazon. While the company prides itself on its scale, the reporting of declining user numbers provides fodder for competitors and regulators who argue that the "Amazon juggernaut" is not invincible. For the European Commission, these figures are vital for monitoring market concentration. If a platform’s reach declines while its market power remains disproportionately high, it may trigger further antitrust scrutiny.

The Future: What These Trends Tell Us

As we look toward the second half of the decade, the data suggests a maturing European e-commerce market. The period of explosive, uniform growth for Amazon has ended. In its place, we are seeing a fragmented reality:

1. Saturation in the Core: The decline in Germany and France suggests that the "low-hanging fruit" of e-commerce has been picked. Future growth here will depend on innovation rather than simple reach.
2. The "Local Hero" Resilience: In markets like Greece and the Netherlands, the endurance of local champions like Skroutz and Bol suggests that European consumers value local expertise, language-specific customer service, and existing retail habits more than a standardized, global shopping experience.
3. The Logistics Edge: The double-digit growth in Scandinavia proves that where Amazon can leverage logistics to offer superior delivery speeds, it can overcome local brand loyalty.

For investors, retailers, and policymakers, these transparency reports are no longer just bureaucratic filings—they are a roadmap of the shifting power dynamics in the European digital economy. Amazon remains the primary force, but the slight decline in its monthly active recipients serves as a reminder that even the largest platforms are subject to the tides of market saturation and the persistent influence of localized competition.

As Amazon continues to navigate the complexities of the Digital Services Act, the company will need to balance its massive scale with the agility required to win over markets where the "Amazon effect" has yet to fully take hold. Whether this current contraction is a temporary blip or the beginning of a long-term leveling off will be the defining question of the next several reporting cycles.