Evidence CalendarEU DMA

EU DMA Article 11 Compliance Report Evidence Calendar

Use this calendar to organize the evidence a designated DMA gatekeeper needs for its Article 11 compliance report and non-confidential summary.

The calendar is grounded in Article 11 and the Commission compliance report template: designation-based timing, annual updates, standalone annexes by core platform service, evidence owners, and review gates.

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Author

Sorena AI

Published

May 9, 2026

Updated

May 9, 2026

Sections

Structured answer sets in this page tree.

Primary sources

Cited legal and guidance references.

Publication metadata

Sorena AI

Published May 9, 2026

Updated May 9, 2026

Overview

Article 11 requires every designated gatekeeper to provide a detailed compliance report to the Commission within six months of designation, publish a non-confidential summary, and keep the report updated at least annually. Track those obligations as milestones with owners, evidence, and review gates.

Section 1

Calendar anchors for Article 11 reporting

Use designation as the starting event for each gatekeeper and designated core platform service. Article 11 ties the first compliance report to the six-month period after designation, and the Commission template expects the report to explain how the gatekeeper demonstrates effective compliance with Articles 5 to 7.

For later cycles, use an annual refresh checkpoint for the compliance report and the non-confidential summary. Do not treat annual refresh as a light editorial update: the template asks prior submitters to highlight differences from the previous version, including relevant annexes.

Designation event: record the Commission designation decision, affected core platform services, and Article 5 to 7 obligations that apply to each service.
First report window: work back from the Article 11 six-month deadline after designation and reserve evidence gates for drafting, owner approval, non-confidential review, and machine-readable packaging.
Annual update: schedule a yearly refresh for the full compliance report and the public non-confidential summary, with a clean version and a marked comparison against the prior submission where a prior report exists.
Interim change trigger: reopen the evidence calendar when new compliance measures are elaborated or put in place, or when events affect DMA compliance, because the template expects ongoing compliance dialogue and reporting.

Sources for this answer

Regulation (EU) 2022/1925 (Digital Markets Act)

Article 11 supplies the six-month post-designation report trigger and the at-least-annual update rule for the report and non-confidential summary.

European Commission - Article 11 DMA compliance report template

The Commission template says prior reports should highlight differences from the previous report and annexes, and it frames reporting as ongoing compliance dialogue.

Section 2

Evidence pack by report section

Build the calendar around the template sections rather than around internal team names. Each reporting cycle should leave a traceable pack for the reporting undertaking, the Article 5 to 7 compliance 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 and applicable obligation. 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.

Section 1 owner: corporate legal or regulatory operations collects the undertaking name, drafting owners, external counsel or expert details, and representation materials where used.
Section 2 owner: product counsel and service owners maintain one annex per core platform service and obligation, with compliance statements, implemented measures, implementation timing, product scope, geographic scope, technical changes, customer-experience changes, and supporting data.
Effectiveness evidence owner: analytics, experimentation, data governance, and engineering teams retain methodology, indicators, disaggregated data where informative, survey or testing outputs, system-monitoring outputs, and raw data readiness records.
Compliance-function owner: the head of compliance function owns evidence about report preparation, compliance-function independence and resources, management-body reports on non-compliance risk, replies, meeting materials, policies, training, and monitoring documents.
Public-summary owner: legal, communications, and confidentiality reviewers prepare a faithful non-confidential summary that follows the compliance report structure and preserves meaningful ranges, baselines, or aggregated data where confidential numerical data cannot be disclosed.

Sources for this answer

European Commission - Article 11 DMA compliance report template

The template defines the minimum report sections, including reporting undertaking details, standalone Article 5 to 7 annexes by core platform service, compliance-function monitoring, non-confidential summary, and declaration.

Regulation (EU) 2022/1925 (Digital Markets Act)

Article 11 requires a detailed and transparent report on measures implemented to ensure compliance with Articles 5, 6, and 7.

Section 3

Calendar rows to maintain for each reporting cycle

A useful evidence calendar should be a working table, not a generic reminder list. Each row should identify the report section, the affected core platform service, the obligation or template item, the evidence artifact, the accountable owner, the source of truth, the review gate, and the 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.

Row type: designation and scope record, with the designated core platform service, case or designation reference, applicable Articles 5 to 7 obligations, and exclusions that the undertaking says cannot apply by nature.
Row type: measure evidence, with pre-designation or post-designation status, implementation date, product and geographic scope, engineering changes, interface or customer-journey changes, terms or remuneration changes, consultation evidence, alternatives considered, and security or privacy justification where relevant.
Row type: effectiveness evidence, with indicators, definitions, calculation notes, testing or survey methodology, monitoring system output, raw data location, and the owner who can produce underlying data if the Commission requests it.
Row type: feedback and response, with business-user or end-user feedback grouped by topic where appropriate, confidentiality preference, action taken, and non-confidential wording for the summary.
Row type: governance evidence, with compliance-function reports to the management body, management replies, policy or strategy approvals, training materials, review meeting date, participants, agenda, and minutes.
Row type: publication package, with machine-readable clean report, annexes, redline or change log, non-confidential summary, confidentiality log, declaration, signatory details, and publication handoff.

Sources for this answer

European Commission - Article 11 DMA compliance report template

The row types mirror the template's requested evidence: measures, implementation details, effectiveness indicators, feedback, compliance-function material, non-confidential summary, and declaration.

European Commission - DMA gatekeepers page

The Commission gatekeepers page identifies designated gatekeepers, core platform services, compliance reports, and other DMA case resources that can anchor company-specific calendar rows.

Section 4

Review gates before submission and publication

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.

The review should cover both the confidential compliance report and the public summary. A strong public summary should not simply redact entire sections; the template points to self-standing text, visible headings, coverage of all sections and sub-sections, and meaningful ranges or aggregated data for confidential numerical material.

Source gate: every obligation, deadline, designated service, exemption or non-applicability claim points to the DMA text, the Commission template, the designation material, or a Commission request.
Completeness gate: each Article 5 to 7 obligation annex has a compliance statement, explanation of measures, supporting data or documents, assessment evidence, feedback handling, and owner sign-off.
Raw-data gate: underlying data used for indicators, testing, surveys, and monitoring is identified and ready to be made available if the Commission asks for it.
Confidentiality gate: the public summary follows the same structure as the report, keeps headings visible, explains omitted confidential material, and uses meaningful ranges, baselines, or aggregated data instead of blank redactions where possible.
Format gate: the compliance report, annexes, non-confidential summary, and underlying data are prepared in machine-readable form with searchable and recognizable text.
Declaration gate: the head of the compliance function signs the submission and annex declarations only after owners have confirmed estimates, opinions, and completeness checks.

Sources for this answer

European Commission - Article 11 DMA compliance report template

The template supports the review gates for machine-readable submissions, raw data readiness, public-summary structure, confidentiality handling, and declaration language.

Regulation (EU) 2022/1925 (Digital Markets Act)

Article 11 requires the non-confidential summary to be published and provided to the Commission, and says the Commission will link to it on its website.

Recommended next step

Turn Article 11 reporting into owners, evidence rows, and review gates

Use the cited sources listed here to verify obligations and the supporting evidence requirements.

Research workflow

Open Research Copilot for DMA reporting

Verify the following areas from the cited sources: Article 11 report sections, evidence categories, annual updates, and public-summary requirements using the cited sources on this page.

Explore next step

Talk to Sorena

Review an evidence calendar

Walk through your DMA Article 11 reporting owners, gaps, source support, and publication gates with Sorena.

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Primary sources

References and citations

European Commission - Article 11 DMA compliance report template

digital-markets-act.ec.europa.eu

Referenced sections

The template supports the review gates for machine-readable submissions, raw data readiness, public-summary structure, confidentiality handling, and declaration language.

"machine-readable format"

European Commission - DMA gatekeepers page

digital-markets-act.ec.europa.eu

Referenced sections

The Commission gatekeepers page identifies designated gatekeepers, core platform services, compliance reports, and other DMA case resources that can anchor company-specific calendar rows.

"core platform services"

European Commission - DMA legislation page

digital-markets-act.ec.europa.eu

Referenced sections

Commission source listing DMA legislation and official DMA templates, including the Article 11 compliance report template.

"Article 11 DMA"

Regulation (EU) 2022/1925 (Digital Markets Act)

eur-lex.europa.eu

Referenced sections

Article 11 requires the non-confidential summary to be published and provided to the Commission, and says the Commission will link to it on its website.