> These are relatively recent and may have come into force after development began, definitely after Siri development an initial integration into personal data.

The DMA was substantially finalised by 2020, and came into force in 2023. Apple's AI thing was developed with the full knowledge that it existed. The issue isn't personal data here (that'd be the GDPR, and maybe to some extent the AI Act). The DMA is about _competition_. The EU's issue here is that Apple is giving its own AI thing a level of access unavailable to other vendors' AI things, I'd assume.

> As a small developer

You are not covered by the DMA. You'd need an EEA turnover of 7.5bn and/or a market cap of 75bn, for a start. And you'd also need to be a _platform_. The DMA only really applies to a few companies.