A source-grounded test for whether a platform service may fall into the Digital Markets Act gatekeeper designation process.
Use it to separate the Article 3 undertaking-level thresholds, service-level EU user thresholds, core platform service categories, notification steps, and evidence needed before a DMA designation assessment.
Structured answer sets in this page tree.
Cited legal and guidance references.
The DMA does not apply to every digital service. The central question is whether an undertaking provides one or more core platform services and is, or could be, designated by the European Commission as a gatekeeper under Article 3. This test turns that question into a service-by-service record: undertaking size, EU user reach, durability over time, notification status, and evidence quality. Timings in this page are source-linked; verify current legal source language before implementation decisions.
Begin with Article 2, not with general platform labels. A service can only move through this applicability test if it fits one of the DMA core platform service categories.
The DMA categories are online intermediation services, online search engines, online social networking services, video-sharing platform services, number-independent interpersonal communications services, operating systems, web browsers, virtual assistants, cloud computing services, and certain online advertising services linked to another listed core platform service.
Article 3 has three substantive criteria: significant impact on the internal market, a core platform service that is an important gateway for business users to reach end users, and an entrenched and durable position or a foreseeable entrenched and durable position.
The quantitative presumption is met where the undertaking reaches the size threshold and the individual core platform service reaches the EU user thresholds. The undertaking-level size threshold is annual Union turnover of at least EUR 7.5 billion in each of the last three financial years, or average market capitalisation or equivalent fair market value of at least EUR 75 billion in the last financial year, plus provision of the same core platform service in at least three Member States.
The user-count step must follow the DMA Annex methodology. It uses unique users counted once for the relevant core platform service over the relevant period: a month for active end users and a year for active business users.
For monthly active end users, the DMA Annex looks to the average number of monthly active end users throughout the largest part of the financial year. For active business users, the count is generally at business-account level where that concept applies.
If the Article 3(2) thresholds are met, the undertaking should prepare a notification for each core platform service that meets the service-level user thresholds. The Commission must designate an undertaking that meets all Article 3(2) thresholds without undue delay and at the latest within 45 working days after receiving complete information.
A notifying undertaking may submit sufficiently substantiated arguments that, despite meeting the thresholds, the relevant core platform service does not satisfy the Article 3(1) requirements. If those arguments manifestly call the presumption into question, the Commission can open the Article 17(3) market-investigation procedure.
The output of the applicability test should be a defensible evidence file, not a yes/no memo. If a designation decision lists a core platform service, the gatekeeper must comply with Articles 5, 6, and 7 within six months after that service is listed.
The Commission's Article 11 compliance-report template shows the type of evidence that later becomes important: per-service and per-obligation explanations, supporting data, internal documents, implementation dates, product and geographic scope, technical or engineering changes, customer-experience changes, terms changes, consultations, alternatives considered, and user communications.
No. Meeting all Article 3(2) thresholds creates a presumption and triggers notification duties, but gatekeeper status comes from Commission designation under Article 3.
The common error is testing a corporate brand or whole product suite instead of each Article 2 core platform service. Article 3 notification and later compliance evidence are service-specific.
Save the Article 2 category analysis, undertaking-level size data, Member State coverage, EU end-user and business-user counts, Annex methodology, three-year threshold history, Form GD materials, and any rebuttal arguments.
Use the cited sources listed here to verify obligations and the supporting evidence requirements.
Verify the following areas from the cited sources: DMA gatekeeper criteria, core platform service scoping, notification records, and compliance evidence using the cited sources on this page.
Review whether a platform service needs a DMA threshold file, Form GD preparation, rebuttal analysis, or post-designation evidence map.
"notification form"
"each core platform service"
"Core platform services"
"designation of gatekeepers"
"Designation Process"
"within 6 months"