Artifact GuideEU

EU Digital Markets Act (DMA) Applicability Test

Scope core platform services (CPS), assess gatekeeper designation likelihood, and identify your first DMA workstreams.

Grounded in Regulation (EU) 2022/1925: CPS definitions, gatekeeper thresholds, notification/designation timing, and the 6-month compliance clock.

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Author

Sorena AI

Published

Feb 21, 2026

Updated

Feb 23, 2026

Sections

Structured answer sets in this page tree.

Primary sources

Cited legal and guidance references.

Publication metadata

Sorena AI

Published Feb 21, 2026

Updated Feb 23, 2026

Overview

This DMA applicability test helps product, legal, compliance, and policy teams answer one question fast: are we (or a partner platform) likely to be a DMA gatekeeper for one or more core platform services in the EU, and if yes, what deadlines and obligations start to matter immediately? As of 6 March 2026, the Commission's public gatekeeper page lists 7 gatekeepers and 23 designated core platform services, which makes CPS-level scoping more important than company-level labels alone.

Section 1

Step 1: Are you providing a core platform service (CPS)?

The DMA applies to core platform services (CPS) provided or offered by gatekeepers to business users established in the EU or end users established or located in the EU.

Start by mapping your products to the CPS categories in the DMA definition. If you provide any CPS category at scale, you should treat DMA scoping as a product requirement and a compliance program.

CPS categories include: 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 online advertising services linked to those CPS categories.
Define CPS boundaries the way engineering ships them: user journeys, authentication, data flows, ranking and recommendation systems, ads stack, and developer interfaces.
Document "CPS vs non-CPS" calls with rationale; these decisions become evidence in Commission questions, stakeholder submissions, and compliance reports.

Section 2

Step 2: Gatekeeper presumption thresholds (Article 3(2))

An undertaking is presumed to meet the gatekeeper conditions when it hits quantitative thresholds on market impact, gateway role, and durability.

Use this as a screening test for each CPS separately (for example: an app store CPS may qualify even if another CPS does not).

Market impact presumption: >= EUR 7.5B annual EU turnover in each of the last 3 financial years OR >= EUR 75B average market capitalisation/fair market value in the last financial year, and the same CPS in at least 3 Member States.
Gateway presumption: in the last financial year, the CPS has >= 45M monthly active end users established or located in the EU AND >= 10,000 yearly active business users established in the EU (calculated using the Annex methodology).
Durability presumption: the gateway thresholds are met in each of the last 3 financial years.

Section 3

Step 3: Notification, designation, and the compliance clock

If you meet all presumption thresholds, the DMA expects a notification to the Commission quickly, with a strict back-and-forth timeline.

This timing matters because the DMA's core obligations (Articles 5-7) must be complied with within 6 months after a CPS is listed in the designation decision.

Notify the Commission without delay and in any event within 2 months after the thresholds are met (including information per CPS).
Commission designation deadline: at the latest within 45 working days after receiving complete information.
Compliance deadline: obligations in Articles 5, 6, and 7 apply within 6 months after the CPS is listed in the designation decision.
Practical filing readiness: keep your case file, signatory workflow, and secure submission channel ready before thresholds are hit, because DMA submissions are handled digitally and delays usually come from incomplete information, not from the form itself.

Section 4

Step 4: What if you don't meet the thresholds (but still look like a gatekeeper)?

The DMA also allows designation based on qualitative assessment when thresholds are not met but the three conditions (market impact, gateway role, durable position) appear satisfied.

Treat "near-threshold" or "structural advantage" signals as early warning indicators and start designing DMA-ready controls before designation.

Qualitative factors include: size/market position, user and business user numbers, network effects and data advantages, scale and scope effects, lock-in and switching costs, and vertical integration/conglomerate structure.
Plan for evidence and defensibility: why a CPS should or should not be listed; what features are "essential" vs "optional"; what integrity/security measures are necessary and proportionate.
Use current Commission outcomes as calibration: the public gatekeeper list now shows 7 gatekeepers and 23 designated CPS, while Facebook Marketplace was undesignated on 23 April 2025 and Apple Ads and Apple Maps were not designated on 5 February 2026 after notification and review.
If you are a business user, competitor, or end user, you can submit information about potential non-compliance to national competent authorities or the Commission.

Section 5

DMA scoping deliverables (what to produce in week one)

A strong DMA applicability test ends with artifacts that product and compliance teams can execute against - not just an "in scope / out of scope" label.

These deliverables also shorten the path to a defensible compliance report if the CPS is designated.

CPS inventory: services, user journeys, APIs, and dependencies (per CPS).
Gatekeeper threshold workbook: EU turnover/market cap, Member State coverage, MAU/BAU methodology assumptions, and confidence ranges.
Owner map: product owners + policy owners for each obligation cluster (data use, ranking, interoperability, choice screens, app distribution, ads transparency).
Evidence plan: what logs, policies, screenshots, demos, and metrics you can produce on demand.

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Primary sources

References and citations

Commission Implementing Regulation (EU) 2023/814 - DMA procedural rules

eur-lex.europa.eu

Referenced sections

Procedural regulation (forms, notifications, conduct of proceedings) supporting DMA implementation and submissions.

DG Competition - EU SEND secure document exchange platform

competition-policy.ec.europa.eu

Referenced sections

How to securely transmit DMA-related documents to the Commission (useful when notifications or submissions are required).

European Commission - Further information about the DMA (Q&A)

digital-markets-act.ec.europa.eu

Referenced sections

Practical guidance on contacts, submissions, and how stakeholders interact with the Commission on DMA implementation.

European Commission - Gatekeepers list and designated core platform services

digital-markets-act.ec.europa.eu

Referenced sections

Concrete examples of designated gatekeepers, CPS listings, and designation dates used to calibrate applicability risk.

Regulation (EU) 2022/1925 (Digital Markets Act) - Official Journal

eur-lex.europa.eu

Referenced sections

Primary legal text for CPS definitions, gatekeeper thresholds, notification/designation procedure, and the 6-month compliance deadline (Articles 2-3).

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