This article examines the fundamental paradox of digital platform governance—platforms as both regulated entities and regulatory instruments. It argues for a dual-axis analytical framework centered on data factor economics and institutional architecture,
The digital platform has become the defining institutional form of twenty-first-century capitalism. Yet for all the scholarly attention lavished on network effects, multisided markets, and algorithmic coordination, one fundamental tension remains persistently undertheorized: platforms are simultaneously the primary objects of digital governance and its most indispensable instruments. This duality—platform as regulated entity and platform as regulatory infrastructure—creates a paradox that conventional antitrust frameworks, designed for an era of tangible assets and linear supply chains, are structurally ill-equipped to resolve.
Over the past eighteen months, this paradox has ceased to be an abstract theoretical curiosity. The European Commission's Digital Markets Act (DMA) entered its first full enforcement cycle, producing precedent-setting fines against Apple and Meta. China's platform economy entered what the Platform Economy Standardized Development Research Report (2025) described as a "concentrated explosion period" of legislation and rule-making, spanning platform governance, data protection, market competition, and rights protection. Meanwhile, the National Data Administration launched its first high-quality datasets for intelligent platform governance, integrating 20 petabytes of multi-source heterogeneous data across sixteen categories to power antitrust analysis, capital penetration review, and online transaction supervision. The regulatory machinery is no longer experimental—it is operational.
What remains unresolved, however, is the analytical framework that should guide it. This article argues that the platform governance challenge cannot be adequately addressed through either the traditional competition-policy lens or the emerging data-rights framework alone. Instead, it requires a dual-axis approach: one axis tracing the economic logic of data as a production factor, the other mapping the institutional architecture through which platforms intermediate, aggregate, and govern economic activity. The intersection of these two axes—what I term the governance-constraint frontier—defines the feasible space within which platform regulation can be both effective and economically sustainable.
Any serious engagement with platform governance must begin with the factor that distinguishes digital platforms from all prior organizational forms: data. Not data as a byproduct, not data as an asset, but data as a production factor—a primary input into value creation that exhibits economic properties fundamentally unlike land, labor, or capital.
Data can be replicated at near-zero marginal cost. Its value does not diminish with use; indeed, it often appreciates. It exhibits what economists call non-rivalry: one firm's use of a dataset does not preclude another's. Yet these benign properties conceal a more troubling corollary. Data's non-rivalry is conditional on access, and access is precisely what platform business models are designed to control. The same technical architecture that enables frictionless data replication also enables frictionless data hoarding.
Consider the scale. In 2025, China's data production reached 52.26 zettabytes, a year-on-year increase of 27.3 percent. The digital economy's core industry value exceeded 14.7 trillion yuan, accounting for more than 10.5 percent of GDP. Yet data trading—the mechanism through which data supposedly realizes its value as a factor—remains stubbornly anemic. National data transaction volume reached 160 billion yuan in 2024, with on-exchange trading doubling to 30 billion yuan. These are not trivial numbers, but they are trivial relative to the underlying data stock. The gap between data production and data utilization is not a market failure; it is a market structure—one deliberately engineered by platforms that derive competitive advantage from data exclusivity.
This structural reality has profound implications for governance. Traditional economic regulation assumes that market power manifests through price. Digital platforms, however, exercise power through access—access to data, access to users, access to the algorithmic infrastructure that matches supply with demand. As the China Digital Platform Governance Research Report (2025) documented, platform power now operates across three distinct dimensions: governance structure, ecosystem governance, and social governance. This tripartite distribution means that regulatory interventions targeting any single dimension will inevitably be circumvented through the others.
The platform's transformation of byproduct data into production tools creates what Zhang and Wu (2025) term "data-empowered network effects"—a feedback loop in which personalization improves service quality, which attracts more users, which generates more data, which further improves personalization. Content platforms, by contrast, leverage data exclusivity directly as their core product, establishing entry barriers through proprietary datasets that competitors cannot replicate. These are distinct monopolization pathways, and they demand distinct regulatory responses—a point to which I will return.
The global response to platform power has coalesced around two broad institutional models, each reflecting distinct legal traditions and political economies. The European model, epitomized by the DMA, is ex ante and structural: it designates gatekeepers, imposes conduct obligations, and mandates interoperability before violations occur. The Chinese model, by contrast, has been ex post and behavioral: it prosecutes specific abuses, issues guidelines, and gradually builds a normative framework through enforcement precedent.
These models are not as divergent as they first appear. Both confront the same underlying challenge: how to regulate entities whose market power derives from control over data and algorithms rather than from control over physical assets or distribution channels. Both have arrived at similar remedial toolkits—interoperability mandates, data portability requirements, prohibitions on self-preferencing, and algorithmic transparency obligations. And both have encountered similar implementation difficulties.
Consider the DMA's enforcement record. By mid-2025, seven firms had been designated as gatekeepers, covering twenty-three core platform services. The Commission levied a €500 million fine against Apple for anti-steering provisions and a €200 million fine against Meta for its "consent or pay" advertising model. Yet these enforcement actions, for all their symbolic weight, address symptoms rather than causes. The DMA's interoperability provisions have produced tangible results—WhatsApp and Messenger now support one-to-one chat interoperability, and third-party providers like BirdyChat and Haiket have begun integrating—but the fundamental asymmetry of data access remains largely undisturbed.
China's approach has been more incremental but no less ambitious. The 2022 revision of the Anti-Monopoly Law added specific provisions on data and algorithm-related monopolistic conduct. The subsequent development of algorithmic record-keeping, deep synthesis management, and generative AI governance frameworks positioned China as the first major jurisdiction to move AI governance from principle to operational practice. The "three laws and one regulation" framework—the Cybersecurity Law, the Data Security Law, the Personal Information Protection Law, and the Administrative Regulations on Network Data Security Management—now provides a comprehensive legal backbone for data governance.
Yet here too, the gap between regulatory aspiration and economic reality remains wide. Government-led data trading platforms, despite substantial policy support, continue to struggle with what Hua and Zhang (2025) identify as "a lack of core competitiveness, insufficient interconnectivity, pronounced data silos, and limited transaction scales". The platforms that actually move data at scale are not the regulated exchanges but the unregulated ecosystems—the same gatekeepers that regulation seeks to constrain.
This brings us to the dimension of the platform governance problem that receives the least attention: the platform's own role as a governance institution. Digital platforms do not merely intermediate economic activity; they constitute the institutional framework within which that activity occurs. They set the rules of participation, enforce those rules through algorithmic mechanisms, adjudicate disputes, and allocate resources—functions that in any other context would be recognized as governance proper.
The implications for regulatory design are non-trivial. When a platform governs its ecosystem through algorithmic allocation of traffic, ranking, or matchmaking, it is exercising a form of regulatory power that is simultaneously more granular and less accountable than any government agency could achieve. The platform knows, in real time, which merchants receive visibility, which workers receive assignments, which content reaches which audiences. This knowledge is not merely informational; it is constitutive—it shapes the very market outcomes that regulation purports to oversee.
The platform economy intelligent governance dataset developed by the China Electronic Technology Group Corporation illustrates the scale of this challenge. By integrating 20 petabytes of data across government administration, enterprise operations, and public internet sources, the system constructs a comprehensive capital network图谱 and deploys over 100 business models for antitrust analysis, capital penetration review, and transaction monitoring. This is governance infrastructure of a sophistication that would have been unimaginable a decade ago. Yet it remains infrastructure for governance, not infrastructure of governance. The platforms themselves are not subject to equivalent transparency requirements regarding their own algorithmic decision-making.
The asymmetry is structural and, I would argue, unsustainable. Regulatory agencies now possess more data about platform behavior than ever before, but they possess less insight into platform decision logic than ever before. The algorithms that determine search rankings, content distribution, and price recommendations are not merely technical artifacts; they are regulatory instruments that operate without the procedural safeguards, appeal mechanisms, or democratic accountability that we expect of public governance institutions.
If the analysis above is correct, then platform governance is not a problem with a solution but a tradeoff with a frontier. At any given point, regulatory interventions generate both benefits (reduced market power, enhanced competition, consumer protection) and costs (reduced innovation incentives, compliance burdens, regulatory arbitrage). The optimal regulatory stance is not the one that maximizes benefits or minimizes costs but the one that operates along the efficient frontier of the governance-constraint tradeoff.
This framing has several implications. First, it suggests that regulatory design should be parametric rather than categorical. Instead of designating entire classes of platforms as gatekeepers subject to uniform obligations, regulators should identify specific governance functions—search ranking, content moderation, price recommendation, labor allocation—and apply calibrated constraints to each. The DMA's recent move to investigate AWS and Azure as potential core platform services, and its parallel industry-wide investigation into cloud computing, reflects an awareness of this need for granularity.
Second, it implies that interoperability mandates and data portability requirements—the current favorites of competition regulators—are necessary but not sufficient. They address the access problem but not the governance problem. A platform that must share data with competitors can still govern its ecosystem through opaque algorithmic rules. The real regulatory frontier lies in algorithmic transparency and procedural accountability—requirements that platforms disclose not just what they decide but how they decide.
Third, it suggests that the distinction between ex ante and ex post regulation is less meaningful than the distinction between structural and behavioral interventions. Structural interventions—breaking up platforms, mandating separation of businesses, imposing ownership restrictions—are blunt instruments with high error costs. Behavioral interventions—conduct obligations, transparency requirements, interoperability mandates—are more precise but require ongoing monitoring and enforcement capacity that few regulators possess.
The Chinese approach, with its emphasis on "constrained—guided" binary frameworks for platform interoperability, its "government—platform—enterprise" tripartite governance architecture, and its development of scenario-based compliance and regulatory mechanisms, reflects an implicit recognition of these tradeoffs. The European approach, with its formal designation processes and graduated obligations, reflects a different institutional logic but confronts the same underlying constraints.
No discussion of platform governance would be complete without acknowledging its international dimension. Digital platforms are global by design; regulatory regimes are national by jurisdiction. This mismatch creates opportunities for regulatory arbitrage that undermine even the most well-designed domestic frameworks.
The "16+1 Cooperation" framework—the platform for economic collaboration between China and sixteen Central and Eastern European countries—offers an instructive case study. Established in 2012 and formalized through a 2015中期规划, this institutional platform was designed to facilitate trade, infrastructure investment, and people-to-people exchange. What makes it relevant to our discussion is not its geopolitical significance but its platform logic: it functions as a governance mechanism that coordinates economic activity across multiple jurisdictions, each with distinct regulatory regimes, legal traditions, and economic priorities.
The "16+1" experience reveals something important about platform governance across borders: the effectiveness of any regulatory framework depends not on its intrinsic design but on its alignment with the institutional capabilities of participating jurisdictions. Platforms that operate across regulatory boundaries—whether they are trade platforms like the SCO economic and trade comprehensive service platform, which has registered 22,000 enterprises and processed cross-border settlements exceeding 550 billion yuan, or digital trade platforms like the China Daji digital trade platform, which cleared 100 million yuan in customs declarations within twenty-one days of operation—cannot be regulated through purely domestic instruments.
The emerging solution, visible in both the EU's regulatory cooperation agreements and China's participation in multilateral digital governance forums, is regulatory convergence through information sharing and best-practice exchange. The European Commission's July 2025 cooperation agreement with Japan's Fair Trade Commission on DMA implementation and China's active participation in global digital competition forums reflect a growing recognition that platform governance, like the platforms themselves, must be multi-jurisdictional.
Yet convergence is not harmonization, and information sharing is not enforcement. The fundamental challenge remains: platforms can relocate data processing, algorithm development, and even legal incorporation to jurisdictions with permissive regimes. The governance-constraint frontier is therefore not a single curve but a family of curves, each reflecting a different jurisdictional configuration. Regulatory competition—the dynamic through which jurisdictions compete to attract platform investment by offering lighter regulatory burdens—may produce a race to the bottom that no single regulator can prevent.
The analysis above suggests several directions for future research. First, we need better empirical measures of platform governance functions. The current focus on market share, user numbers, and revenue obscures the qualitative dimensions of platform power—the extent to which platforms control the rules of economic participation. Second, we need comparative institutional analysis that evaluates the performance of different regulatory models not in isolation but in interaction. The DMA and China's platform governance framework are not alternatives; they are complements that together define the global regulatory environment. Third, we need dynamic models that account for platform adaptation. Platforms are not passive objects of regulation; they actively shape, circumvent, and sometimes co-opt regulatory interventions. Any governance framework that does not account for this strategic behavior is unlikely to achieve its objectives.
The stakes are considerable. Digital platforms now mediate a growing share of global economic activity. Their governance structures determine not just market outcomes but the distribution of economic opportunity, the conditions of work, and the terms of social participation. Getting platform governance right is not merely a technical regulatory challenge; it is a fundamental question of economic justice and institutional design.
The paradox with which I began—platforms as both objects and instruments of governance—is not a problem to be solved but a condition to be managed. The governance-constraint frontier defines the space within which effective regulation is possible. Our task is not to transcend that frontier but to map it, understand its contours, and operate within its constraints while pushing its boundaries through institutional innovation and analytical rigor.
That is the work that lies ahead.
Source Reference Link: https://wiki.mbalib.com/wiki/16+1合作
Content Disclaimer: This article is for general reference only and does not constitute professional R&D guidance, production process advice, or quality certification. All material performance data has specific test premises; readers should verify parameters against actual equipment and working conditions.

