A focused review format for product, interface, commercial, contractual, and technical changes that could undermine a gatekeeper's DMA obligations.
Use it to map a change to Articles 5, 6, and 7, test whether rights or choices become harder to exercise, and preserve evidence suitable for Article 11 compliance reporting.
DMA Article 13 prohibits service fragmentation used to avoid Article 3 thresholds and conduct that undermines effective compliance with Articles 5, 6, and 7, including contractual, commercial, technical, behavioural, and interface-design choices. Start with the listed and exact underlying obligation. The review should end with a recorded pass, conditional pass with required changes, or block decision, plus the evidence and monitoring trigger. Security, integrity, or privacy restrictions are available only where the mapped obligation permits them and their stated conditions are met.
Run this review before a designated gatekeeper changes a , adjacent support service, user interface, application programming interface (API), ranking system, consent flow, access condition, fee model, business-user term, interoperability process, data-access process, or enforcement workflow that implements or touches a DMA Article 5, 6, or 7 obligation.
The review should also cover changes that split a service, recategorize usage, move functionality between services, add friction to an alternative channel, or change how users exercise a DMA right. Article 13 expressly covers segmentation or fragmentation used to circumvent designation thresholds and behavior that undermines effective compliance.
Keep the pre-designation threshold branch separate from the gatekeeper-compliance branch. Article 13(1) addresses an undertaking providing core platform services that fragments them to avoid thresholds. Article 13(3) to (8) addresses a gatekeeper's full and effective compliance with Articles 5, 6, and 7.
Sources (2)
Article 13 is the legal basis for reviewing segmentation, contractual, commercial, technical, behavioral, and interface-design choices that could circumvent DMA obligations.
shall not engage in any behaviour that undermines effective compliance
Commission page for checking current gatekeeper undertakings and listed core platform services before scoping a design review.
Core platform services
The question depends on the underlying obligation. A payment-flow change should be tested against the Article 5 and Article 6 rights it affects; an API or operating-system change should be tested against the relevant interoperability or access obligation; a consent or choice-screen change should be tested against whether the user's choice remains neutral and practicable.
Do not approve a change only because the formal obligation text is still mentioned in policy. The review has to test whether the implemented product path remains effective for the business user, end user, advertiser, publisher, developer, or third-party provider that the obligation is meant to protect.
Sources (2)
Articles 5, 6, and 7 define the obligations whose effective compliance must not be undermined by Article 13 circumvention.
The gatekeeper shall ensure that the obligations
Commission legislation page identifies the DMA as the main rules for gatekeeper designation and implementation of obligations and prohibitions.
designation of gatekeepers and the implementation of the obligations
A design review should have stop conditions, not just comments. If a change affects a DMA right, the approver should be able to point to a test result, user journey, or technical record showing that the right remains usable and that any security, integrity, or privacy restriction is justified and proportionate.
Article 13 makes interface structure, design, function, and manner of operation relevant. That means testing for interface choices that steer or obstruct users, neutral presentation checks, friction analysis, and degradation checks belong in the product release control. A security, integrity, or privacy concern is not a free-standing Article 13 exception; the underlying obligation must permit the measure, and the gatekeeper must satisfy that obligation's necessity, proportionality, and justification conditions.
Sources (2)
Article 13 expressly covers degradation, non-neutral choices, and user-interface design that subverts autonomy, decision-making, or free choice.
structure, design, function or manner of operation
Commission template asks gatekeepers to report technical and engineering changes, customer-interface changes, testing, indicators, and supporting data for each obligation.
technical/engineering changes
The evidence pack should let a reviewer reconstruct how the change affected a specific DMA obligation. Article 11 reporting expects detailed and transparent descriptions of compliance measures, and the Commission template asks for product scope, geographic scope, technical changes, customer-experience changes, consultations, alternatives, testing, indicators, and monitoring tools.
For , keep both approval evidence and rejected alternatives. The rejected-alternatives record is important where a gatekeeper chooses a more restrictive access path, warning, choice architecture, fee rule, or technical limitation.
Sources (1)
Commission template supports the evidence fields for measures, user journeys, testing, indicators, raw data, monitoring systems, and assessment projects.
Run this checklist at the release gate for DMA-relevant product and policy changes. The goal is to show that the change preserves effective compliance, not merely that the team considered DMA in general terms.
The checklist should be attached to the product-change record and reused when the same feature is localized, extended to another , or changed after user feedback.
For an operational example, suppose a proposed warning adds two confirmation screens only to a protected alternative route. The product owner records both paths and their completion data, while the legal reviewer identifies the affected obligation and tests the justification. A conditional pass should name the required redesign, its owner, and the evidence needed to close it before release; the label alone should not authorise the unresolved design.
Article 13 adds an test. A gatekeeper should check whether a design, interface, contractual term, commercial condition, technical measure, behavioral technique, or service split undermines effective compliance with Articles 5, 6, or 7, even if the formal product policy still refers to the DMA obligation.
The strongest evidence ties the change to a specific and DMA obligation, then shows the before-and-after user journey, technical implementation, access conditions, testing or indicators, complaints or feedback, rejected alternatives, and any security, integrity, or privacy justification.
The DMA allows certain strictly necessary and proportionate security, integrity, or privacy measures in specific obligations, but the gatekeeper should document the reason, the affected right, the alternatives considered, and why the chosen measure does not make the right unduly difficult to exercise.
No. Article 13(1) applies to an undertaking providing core platform services and prevents it from splitting or fragmenting services to circumvent the Article 3(2) thresholds. Article 13(3) to (8) governs a designated gatekeeper's full and effective compliance with Articles 5, 6, and 7.
Sources (2)
Article 13 supports the checklist focus on effective compliance, non-neutral choices, degradation, and interface-design circumvention.
make the exercise of those rights or choices unduly difficult
Commission template supports the checklist requirement for implementation detail, testing, indicators, monitoring tools, and user or business-user feedback.
internal systems and tools used to monitor
Sorena can help convert this DMA anti-circumvention review into product-change questions, obligation mapping, evidence requests, and compliance-report-ready records.
Check Article 13, gatekeeper obligations, design changes, and evidence records against the cited DMA sources.
Review a DMA-relevant product change, map it to Articles 5, 6, or 7, and identify the evidence needed before release.
"Anti-circumvention"
"shall not engage in any behaviour that undermines effective compliance"
"The gatekeeper shall ensure that the obligations"
"structure, design, function or manner of operation"
"make the exercise of those rights or choices unduly difficult"
"detailed and transparent manner"
"technical/engineering changes"
"internal systems and tools used to monitor"
"Gatekeepers"
"Core platform services"
"main rules for the designation of gatekeepers"
"designation of gatekeepers and the implementation of the obligations"
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