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 practical result is an obligation-by-obligation dossier, not a single general compliance narrative.

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 then 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 source-linked: 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; it keeps the evidence current enough to support the next report, update, or Commission request.

Before submission, test the package as a regulator would receive it: the report should be complete, searchable, signed where required, and linked to retrievable evidence. Commission procedural rules for DMA document transmission say digital submissions are the default, digitally transmitted documents need at least one qualified electronic signature, and receipt is tied to the Commission's acknowledgement.

A final filing review should therefore cover content, confidentiality, format, signature, and transmission. It should also confirm that inoperable, unusable, infected, or unverifiable-signature files are not included, because the procedural rules say those documents can be deemed not received.