DMA Article 11 Compliance Reporting

DMA Article 11 requires each gatekeeper to provide the Commission with a report within 6 months after designation. The report must describe the measures implemented to ensure compliance with Articles 5, 6, and 7, and the gatekeeper must update the report and the non-confidential summary at least annually.

Article 8 supplies the test the report has to meet: the gatekeeper must ensure and demonstrate compliance, and the measures must be effective in achieving the objectives of the DMA and of the relevant obligation. The report therefore needs an obligation-by-obligation dossier rather than one general compliance narrative.

Submitting a report does not amount to Commission approval of the measures. Article 11 is binding law; the Commission template states the minimum information gatekeepers should provide and may be updated. Use the latest official template, but keep the statutory deadline and duties separate from Sorena's evidence-management recommendations.

The Commission template asks for information about the reporting undertaking, the people who drafted the report, external counsel or technical experts involved, and separate standalone annexes for each designated core platform service.

For each applicable obligation, the template expects a compliance confirmation statement plus an exhaustive explanation of how the undertaking complies. That explanation should include supporting data and internal documents, and the gatekeeper should have underlying raw data ready if the Commission asks for it.

The report should make each Article 5, 6, or 7 obligation reviewable without asking the Commission or a third party to infer how the control works. Each row in the evidence matrix should connect the legal obligation, the affected service, the implemented measure, the product facts, and the proof of effectiveness.

If an obligation cannot by nature apply to a relevant core platform service, the template allows that information to be omitted only when the undertaking explains why the obligation cannot apply. That is different from an Article 9 suspension or Article 10 exemption request.

Article 11 requires the gatekeeper to publish and provide the Commission with a non-confidential summary within the same deadline as the compliance report. The Commission makes a link to that summary available on its website.

The Commission template says the non-confidential summary should give a faithful and meaningful picture of the report, follow the same structure, cover all sections and subsections, and use separate standalone annexes for each core platform service for Section 2. Redactions should not hollow out the summary: for confidential numerical data, the template asks for meaningful ranges, baseline levels, or aggregated data rather than complete removal.

The legal cadence should stay narrow and cited: the first Article 11 report is due within 6 months after designation, and the report and non-confidential summary must be updated at least annually. The Commission template also expects gatekeepers to highlight differences from a previously submitted report, including relevant annexes.

Operationally, the reporting process should run continuously because the template refers to regular compliance dialogue and ongoing reporting when new compliance measures are developed or events affect DMA compliance. That does not supersede the Article 11 deadline or create one universal interim filing date; it keeps the evidence current enough to support the next report, update, or Commission request.

Trigger an out-of-cycle review when a designation decision adds or removes a service, a Commission specification or non-compliance decision changes the expected measure, a reported product flow or term changes, an indicator materially deteriorates, or complaints reveal that a reported right is not effective in practice.

Before submission, check the package for completeness, searchable text, required signatures, and retrievable evidence. Commission Implementing Regulation (EU) 2023/814 says DMA documents are transmitted digitally by default, digitally transmitted documents must carry at least one qualified electronic signature, and the Commission's acknowledgement determines the receipt date.

The filing review should cover content, confidentiality, format, signature, and transmission. A digitally transmitted file can be deemed not received if it is inoperable or unusable, contains malware or another threat, or contains an electronic signature whose validity the Commission cannot verify. The Commission must notify the sender and allow a reasonable opportunity to respond and correct the problem.