EU DMA Article 11 Compliance Report Evidence Calendar

Use the undertaking's designation as the starting event for the first Article 11 report. Do not create a new initial Article 11 clock merely because the Commission later lists another service for an already designated gatekeeper. The later service has its own Article 3(10) six-month compliance clock; incorporate it into the applicable Article 11 update and follow any requirement in the later decision or Commission correspondence.

For later cycles, set an annual refresh checkpoint for both the compliance report and the non-confidential summary. Article 11 says at least annually but does not set one universal filing date. The Commission template asks prior submitters to highlight differences from the previous report, summary, and relevant annexes, for example through a redline plus a clean version.

The Commission template is guidance on the minimum information it expects, not a replacement for the binding regulation or a designation decision. Check the Commission's legislation page for the current template before each cycle because the template says the Commission may update it.

Keep Article 11 separate from other gatekeeper deliverables. Article 14 concentration notices use the agreement, public-bid announcement, acquisition-of-control, and pre-implementation triggers. Article 15 uses a separate six-month post-designation clock for an independently audited description of consumer-profiling techniques and its public overview. Neither belongs inside an Article 11 annex merely because the same compliance function coordinates the work.

Build the calendar around the template sections rather than internal team names. Each cycle should leave a traceable pack for the reporting undertaking, the Article 5 to 7 annexes, the compliance-function and monitoring section, the non-confidential summary, and the declaration.

For Section 2, use one standalone annex per designated core platform service, covering its applicable obligations. The evidence pack should connect each compliance statement to the measure implemented, the affected product or service scope, the technical or engineering changes, the user or business-user changes, and the data or documents that support effectiveness.

Use a working table for the evidence calendar. Each row should identify the report section, affected core platform service, obligation or template item, evidence artifact, accountable owner, source of truth, review gate, and export format.

Do not add fixed public dates unless they come from the relevant designation decision or a Commission request. The stable cadence supported by Article 11 is the first six-month post-designation report and at-least-annual updates.

As an internal planning example, use the confirmed filing date as day zero: collect service-owner evidence six weeks before it, review gaps and indicator calculations four weeks before it, and complete confidentiality and public-summary review two weeks before it. Reserve the final week for the compliance-function declaration and submission/publication handoff. These are planning checkpoints; adjust them to the undertaking's filing date and complexity without moving the legal deadline.

Use review gates to stop weak Article 11 submissions before they become public or regulator-facing. The Commission template expects true, correct, and complete information, machine-readable files, and a non-confidential summary that lets third parties provide meaningful input.

Review both the confidential report and the public summary. The template does not support blanking entire sections without explanation: it calls for self-standing text, visible headings, every section and subsection, and meaningful ranges or aggregated data where figures are confidential.