Does meeting the DMA quantitative thresholds automatically mean a company is already a ?
No. Meeting all Article 3(2) thresholds creates a presumption and triggers notification duties, but status comes from Commission designation under Article 3.
An official source test for whether a platform service may fall into the Digital Markets Act 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.
The DMA does not apply to every digital service. The central question is whether an undertaking provides one or more core platform services to business users established in the Union or end users established or located in the Union and is, or could be, designated by the European Commission as a under Article 3. The provider's own place of establishment does not decide territorial scope. This test creates a service-by-service record of undertaking size, EU user reach, durability, notification status, and supporting evidence.
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.
Sources (2)
Article 2 defines gatekeepers and lists the core platform service categories used as the first applicability gate.
core platform service
Shows how the Commission identifies designated gatekeepers by undertaking and by listed core platform service.
Core platform services
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.
Sources (2)
Article 3 sets the gatekeeper criteria, the quantitative presumptions, the two-month notification duty, and the Commission designation deadline.
Designation of gatekeepers
Commission overview explaining that the DMA contains the main rules for gatekeeper designation and the obligations imposed on them.
designation of gatekeepers
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. The Annex then defines the activity indicator separately for each service category, so a sign-in count cannot be reused automatically across search, intermediation, advertising, operating-system, browser, cloud, or messaging services.
Sources (2)
The Annex specifies how to identify and calculate active end users and active business users for Article 3(2)(b).
active end users
Procedural implementing rules include Form GD, used by potential gatekeepers when providing designation-process figures to the Commission.
Form GD
If all Article 3(2) thresholds are met, the undertaking must notify the Commission without delay and in any event within two months, identifying each core platform service that meets the service-level user thresholds. The Commission must designate an undertaking that meets the presumptive thresholds without undue delay and at the latest within 45 working days after receiving complete information, unless sufficiently substantiated arguments manifestly call the presumption into question.
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.
Sources (3)
Article 3 covers notification, substantiated rebuttal arguments, designation timing, and listing of core platform services in the designation decision.
within 45 working days
Commission Q&A identifies Form GD, designation-process contact points, and the observation opportunity where preliminary views depart from the notification.
Designation Process
Sets procedural rules for DMA notifications and includes the Form GD notification form.
notification form
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 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.
Record one of four outcomes for each service: outside the Article 2 core-platform-service categories; within a category but below one or more presumptive thresholds and not designated; notification required because all Article 3(2) presumptions are met; or designated by Commission decision. The second outcome still needs monitoring because Article 3(8) permits designation after a market investigation without every quantitative threshold.
No. Meeting all Article 3(2) thresholds creates a presumption and triggers notification duties, but 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, materials, and any rebuttal arguments.
A below-threshold result means the Article 3(2) quantitative presumption and its notification duty are not fully met for that assessment. It does not prevent Commission designation under Article 3(8) after a market investigation. Keep the category rationale, counts, methodology, qualitative Article 3(1) assessment, and reassessment trigger.
Sources (2)
Article 3(10) sets the six-month compliance point after a core platform service is listed in a designation decision.
within 6 months
Commission template identifies the per-core-platform-service and per-obligation evidence expected in DMA compliance reporting.
each core platform service
Use the cited sources listed here to verify obligations and the supporting evidence requirements.
Check DMA gatekeeper criteria, service scope, notification records, and compliance evidence against the cited sources.
Review whether a platform service needs a DMA threshold file, Form GD preparation, rebuttal analysis, or post-designation evidence map.
"Designation of gatekeepers"
"core platform service"
"active end users"
"within 45 working days"
"within 6 months"
"notification form"
"Form GD"
"Compliance Report"
"each core platform service"
"Gatekeepers"
"Core platform services"
"The DMA contains the main rules"
"designation of gatekeepers"
"Designation Process"
Review DMA Article 13 anti-circumvention risks in gatekeeper product, interface, contractual, commercial, and technical changes with obligation mapping and evidence records.
Official source guide to EU Digital Markets Act Article 6 data access for business users, end users, authorised third parties, consent boundaries, and evidence handoffs.
Official source guide to DMA interoperability duties: Article 6(7) operating-system feature access, Article 7 messaging interoperability, request handling, security conditions, and compliance evidence.
Map EU Digital Markets Act Articles 5, 6 and 7 obligations to affected core platform services, product evidence, legal owners, and Article 11 compliance-report artifacts.
Build a DMA compliance program around Article 8 effective compliance, Article 11 reporting evidence, Article 13 anti-circumvention controls, and Article 28 compliance-function governance.
Scope EU Digital Markets Act core platform services by service category, designation evidence, user thresholds, and Form GD service-boundary records.
Build a DMA core platform service obligation matrix that links each designated CPS to Articles 5, 6 and 7 duties, product owners, designation evidence, Article 11 report artifacts and review gates.
Build an official source DMA designation intake record covering core platform service classification, Article 3 thresholds, Form GD evidence, Commission handoff, and Article 11 readiness.
Follow DMA enforcement from investigation and preliminary findings to non-compliance decisions, fines, daily payments, interim measures, commitments, and remedies.
A cited EU Digital Markets Act checklist for designated gatekeepers: core platform service scope, Article 5/6/7 controls, Article 11 report evidence, anti-circumvention checks, and review gates.
A cited EU Digital Markets Act guide for assessing Article 3 gatekeeper thresholds, scoping core platform services, preparing Form GD evidence, handling rebuttal annexes, and planning Article 11 compliance reporting.
Compare DMA Article 30 fine ceilings, the narrow 20% repeat test, 1% procedural fines, and Article 31 daily payments, with decision-specific examples.
Review DMA-relevant product releases for Article 5, Article 6, Article 7, anti-circumvention, Article 11 evidence, and product-owner/legal signoff.
Examples and release-review controls for DMA Article 6(5) self-preferencing checks across ranking, indexing, crawling, search results, marketplaces, app stores, feeds, and virtual assistants.
Compare the EU Digital Markets Act and EU Data Act by scope, actors, data access, interoperability, reporting, evidence, and enforcement without merging distinct obligations.
Compare the EU Digital Markets Act and Digital Services Act by covered services, regulated actors, core duties, reporting, dates, evidence, and enforcement.
Compare the EU Digital Markets Act with EU competition law: ex ante gatekeeper and core platform service duties, Articles 5 to 7, Article 11 reports, penalties, and evidence records.
Compare DMA gatekeeper duties with GDPR rules for personal-data processing, consent, lawful basis, portability, accountability evidence, and enforcement.
Build a DMA Article 11 compliance-report calendar with the correct designation trigger, service annexes, evidence owners, annual updates, and publication gates.
A source-grounded Sorena DMA checklist for designated gatekeepers and core platform services, covering scope, Articles 5, 6 and 7 obligations, Article 11 reporting, evidence, anti-circumvention, and governance.
DMA compliance guide for designated gatekeepers: core platform service scoping, Articles 5, 6 and 7 controls, Article 11 reports, anti-circumvention checks, interoperability evidence, and enforcement risk.
Calculate DMA notification, designation, service-compliance, Article 11 reporting, concentration-notice, and profiling-audit deadlines from the correct legal trigger.
Concise FAQ on the EU Digital Markets Act for gatekeeper designation, core platform services, Articles 5, 6 and 7 obligations, Article 11 reports, interoperability, business-user data access, compliance evidence, and enforcement.
DMA requirements for designated gatekeepers: core platform service scope, Articles 5, 6 and 7 obligations, Article 11 reporting, anti-circumvention, evidence, remedies, and fines.
DMA timeline separating fixed legal dates, threshold and designation clocks, recurring reports, service-specific decisions, final enforcement, and the first Article 53 review.
Official source guide to EU Digital Markets Act Article 11 compliance reports: report purpose, template evidence, non-confidential summaries, annual updates, and submission steps.
Product release checks for designated DMA gatekeepers: Article 5, 6 and 7 obligations, anti-circumvention review, data access, interoperability, self-preferencing and Article 11 evidence.
How gatekeepers should use the DMA Article 11 compliance report template to document obligation-by-obligation measures, evidence, updates, and non-confidential summaries.
FAQ on EU Digital Markets Act core platform services: Article 2 service categories, gatekeeper designation evidence, user thresholds, service scoping, and Article 11 reporting.
Standalone FAQ on the EU Digital Markets Act gatekeeper thresholds, Article 3 notification timing, Form GD evidence, and active user-count methodology.
How DMA Article 7 messaging interoperability requests work, including phased functions, the three-month operational deadline, reference offers, evidence, and safeguards.
FAQ explaining how EU Digital Markets Act Articles 5, 6, and 7 group gatekeeper obligations, what product evidence they require, and how Article 11 reporting connects.