A lot of regulation is legally defined in terms of outcomes. That in itself isn't unusual. Checklists of technical requirements are almowt always a derivative and a suggestion about a safe path to meet the regulated outcome. This is how "blessed" standards for e.g. medical devices work. This shields the laws themselves from overly technical discussions.
The only difference that I can see here is that the standards layer hasn't solidified yet.
That’s a good point. So maybe another point of divergence here is that the outcomes of the DMA are rooted in inherently unpredictable market interactions, whereas a medical device standard depends on the device performance and characteristics.
I don’t think it makes sense to create an accountability framework for a company that requires the cooperation of the market, because I think companies should be in a position to either comply or be held accountable on their own merits