--- title: "EU DMA Article 11 Compliance Reporting Guide" canonical_url: "https://www.sorena.io/artifacts/eu/digital-markets-act/article-11-reporting" source_url: "https://www.sorena.io/artifacts/eu/digital-markets-act/article-11-reporting" author: "Sorena AI" description: "Source-grounded guide to EU Digital Markets Act Article 11 compliance reports: report purpose, template evidence, non-confidential summaries, annual updates, and submission steps." published_at: "2026-05-09" updated_at: "2026-05-09" keywords: - "EU Digital Markets Act" - "DMA Article 11" - "compliance report" - "non-confidential summary" - "gatekeeper reporting" - "DMA" - "Article 11 reporting" - "gatekeeper" - "core platform service" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # EU DMA Article 11 Compliance Reporting Guide Source-grounded guide to EU Digital Markets Act Article 11 compliance reports: report purpose, template evidence, non-confidential summaries, annual updates, and submission steps. *Artifact Guide* *EU DMA* ## DMA Article 11 Compliance Reporting Build an Article 11 compliance report that explains, obligation by obligation, how a designated gatekeeper ensures and demonstrates compliance with DMA Articles 5, 6, and 7. Grounded in Regulation (EU) 2022/1925, the Commission's Article 11 compliance report template, and Commission procedural material for public summaries and report submission. Article 11 reporting is the DMA evidence pack for designated gatekeepers. It is not a policy memo: the report must describe, in a detailed and transparent way, the measures implemented for Articles 5, 6, and 7, and it must be paired with a non-confidential summary that can be published and understood by third parties. Timings in this page are source-linked; verify current legal source language before implementation decisions. ## What the Article 11 compliance report is for 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. - Start from the designation decision and list each designated core platform service. - For each core platform service, map every applicable Article 5, 6, and 7 obligation. - For each mapped obligation, state the measure, implementation status, evidence, responsible team, and effectiveness indicators. - Track the Article 11 report, non-confidential summary, annexes, and underlying data as one controlled reporting package. Sources for this answer: - [Regulation (EU) 2022/1925 (Digital Markets Act)](https://eur-lex.europa.eu/eli/reg/2022/1925/oj?ref=sorena.io) - Article 11 sets the report, non-confidential summary, 6-month submission point, and at-least-annual update requirement. - [European Commission DMA legislation and templates page](https://digital-markets-act.ec.europa.eu/legislation_en?ref=sorena.io) - Commission page listing the DMA legal texts and the Article 11 compliance report template used to structure submissions. ## Template evidence to collect before drafting 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. - Create one annex per designated core platform service and keep the obligation mapping inside that annex. - Capture whether each measure was already in place before designation or implemented after designation. - For each measure, record the prior situation, implementation date, product, service and device scope, geographic scope, and any extension beyond the EEA. - Attach technical and engineering evidence such as data-flow changes, API changes, OS functionality changes, ranking or advertising-auction parameter changes, metrics, demos, and screenshots where relevant. - Attach customer-experience evidence such as choice screens, consent flows, warning messages, system updates, available functionalities, and click-by-click user journeys where relevant. - Keep the raw data, definitions, and calculation explanations behind reported indicators so the report can be tested. Sources for this answer: - [European Commission Article 11 DMA compliance report template](https://digital-markets-act.ec.europa.eu/legislation_en?ref=sorena.io) - The template specifies the minimum information gatekeepers should provide, including separate annexes, compliance statements, supporting data, and internal documents. ## Obligation-by-obligation evidence matrix 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. - Use columns for core platform service, DMA obligation, applicability position, compliance statement date, measure owner, implementation date, and evidence location. - For user-interface obligations, include the live flow, pre-change flow, choice-screen copy, consent-rate data where relevant, and testing methodology. - For data, interface, or technical-access obligations, include access procedure, format, frequency, terms, security controls, retention policies, and whether the access can be independently audited. - For business-user effects, include changes to fees, revenue shares, terms and conditions, pricing-policy clauses, negotiated agreements, and feedback or complaints from Union business users. - For effectiveness, include indicators chosen for the specific obligation and explain why those indicators show whether the measure achieves the DMA objective. - Where the matrix records non-applicability, cite the specific obligation text and explain why the obligation cannot by nature apply to that core platform service. Sources for this answer: - [Regulation (EU) 2022/1925 (Digital Markets Act)](https://eur-lex.europa.eu/eli/reg/2022/1925/oj?ref=sorena.io) - Article 8 requires gatekeepers to ensure and demonstrate effective compliance with Articles 5, 6, and 7. - [European Commission Article 11 DMA compliance report template](https://digital-markets-act.ec.europa.eu/legislation_en?ref=sorena.io) - The template details the obligation-level evidence expected for measures, technical changes, user experience changes, market testing, indicators, and access procedures. ## Non-confidential summary and confidentiality handling 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. - Draft the public summary beside the full report so headings, section coverage, and obligation order stay aligned. - Mark each proposed redaction as business secret, other confidential information, or not confidential. - For each redaction, keep a clear non-confidential description of what was removed and why. - Replace sensitive underlying numbers with ranges, baselines, or aggregated values where the template calls for a meaningful public picture. - Ask business users that submitted feedback whether they request anonymity or confidentiality, and describe actions taken on feedback in non-confidential form. Sources for this answer: - [Regulation (EU) 2022/1925 (Digital Markets Act)](https://eur-lex.europa.eu/eli/reg/2022/1925/oj?ref=sorena.io) - Article 11 requires publication and Commission submission of the non-confidential summary and Commission linking to that summary. - [European Commission Article 11 DMA compliance report template](https://digital-markets-act.ec.europa.eu/legislation_en?ref=sorena.io) - Section 4 of the template explains the structure and content expected in the non-confidential summary. - [Commission guidance on confidentiality claims in competition procedures](https://ec.europa.eu/competition-policy/document/download/ea2cbf27-412c-4394-b872-dd4b4e3a840b_en?ref=sorena.io) - Referenced by the Article 11 template for identifying business secrets and other confidential information in public versions. ## Submission, update, and operating cadence 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. - Maintain a change log for every measure, annex, indicator, source dataset, and public-summary redaction. - When a product or policy change affects a DMA measure, update the obligation row before the next formal report cycle. - When an annual update is prepared, produce a clean version and a redline or equivalent comparison against the prior report and public summary. - Keep the report, annexes, public summary, and underlying data machine-readable with searchable and recognizable text. - Check the latest Commission template before submission because the Commission states that it may update the template and request further information, testing, indicators, or measures. Sources for this answer: - [Regulation (EU) 2022/1925 (Digital Markets Act)](https://eur-lex.europa.eu/eli/reg/2022/1925/oj?ref=sorena.io) - Article 11 is the source for the 6-month first report and at-least-annual update cadence. - [European Commission Article 11 DMA compliance report template](https://digital-markets-act.ec.europa.eu/legislation_en?ref=sorena.io) - The template supports redline/update handling, machine-readable submissions, latest-template checks, and ongoing compliance-dialogue expectations. ## Practical filing controls before submission 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. - Run a completeness check against Sections 1 to 5 of the Commission template. - Verify that each annex has a matching non-confidential summary section and that all headings remain visible. - Confirm that the head of the compliance function can sign the declaration that the submission is true, correct, and complete to the best of their knowledge and belief. - Check machine readability, file integrity, malware scanning, and qualified electronic signature validation before transmission. - Save the Commission acknowledgement of receipt with the submitted package and retain the exact version sent. Sources for this answer: - [Commission Implementing Regulation (EU) 2023/814](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R0814&qid=1683206721235&ref=sorena.io) - Procedural rules for DMA document transmission, qualified electronic signatures, acknowledgement of receipt, and files that may be deemed not received. - [European Commission Article 11 DMA compliance report template](https://digital-markets-act.ec.europa.eu/legislation_en?ref=sorena.io) - The template provides the declaration text and final report structure used for the submission package. *Recommended next step* *Placement: before sources* ## Prepare a service-by-service Article 11 report Use the cited sources listed here to verify obligations and the supporting evidence requirements. - [Open Research Copilot for DMA Article 11](/solutions/research-copilot.md): Verify the following areas from the cited sources: Article 11 report scope, evidence fields, public summaries, and submission controls using the cited sources on this page. - [Review a DMA reporting evidence matrix](/contact.md): Check whether your Article 11 annexes, measures, indicators, and non-confidential summary line up with the Commission template. ## Primary sources - [Regulation (EU) 2022/1925 (Digital Markets Act)](https://eur-lex.europa.eu/eli/reg/2022/1925/oj?ref=sorena.io) - Primary DMA source for Article 11 reporting, non-confidential summary publication, annual updates, and Article 8 compliance-demonstration requirements. - Quote: "The gatekeeper shall update that report" - [European Commission DMA legislation and templates page](https://digital-markets-act.ec.europa.eu/legislation_en?ref=sorena.io) - Commission page listing the Article 11 compliance report template and other DMA forms used for gatekeeper submissions. - Quote: "Article 11 DMA - Compliance Report Template Form" - [European Commission Article 11 DMA compliance report template](https://digital-markets-act.ec.europa.eu/legislation_en?ref=sorena.io) - Template support for the report structure, service-by-service annexes, obligation-level evidence fields, non-confidential summary, and declaration. - Quote: "for each core platform service" - [Commission Implementing Regulation (EU) 2023/814](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R0814&qid=1683206721235&ref=sorena.io) - Procedural source for transmitting DMA documents to and from the Commission by digital means and handling receipt issues. - Quote: "signed using at least one Qualified Electronic Signature" - [Commission guidance on confidentiality claims in competition procedures](https://ec.europa.eu/competition-policy/document/download/ea2cbf27-412c-4394-b872-dd4b4e3a840b_en?ref=sorena.io) - Confidentiality guidance referenced by the Article 11 template for public versions and non-confidential summaries. - Quote: "business secrets and other confidential information" ## Related Topic Guides - [DMA Anti-Circumvention Design Review for Gatekeeper Product Changes](/artifacts/eu/digital-markets-act/anti-circumvention-design-review.md): Review DMA Article 13 anti-circumvention risks in gatekeeper product, interface, contractual, commercial, and technical changes with obligation mapping and evidence records. - [DMA Article 11 Compliance Report Template FAQ](/artifacts/eu/digital-markets-act/faq/compliance-report-template.md): How gatekeepers should use the DMA Article 11 compliance report template to document obligation-by-obligation measures, evidence, updates, and non-confidential summaries. - [DMA Article 6 Business User Data Access Guide](/artifacts/eu/digital-markets-act/business-user-data-access.md): Grounded guide to EU Digital Markets Act Article 6 data access for business users, end users, authorised third parties, consent boundaries, and evidence handoffs. - [DMA Article 6(7) and Article 7 interoperability obligations](/artifacts/eu/digital-markets-act/article-6-7-interoperability.md): Grounded guide to DMA interoperability duties: Article 6(7) operating-system feature access, Article 7 messaging interoperability, request handling, security conditions, and compliance evidence. - [DMA Articles 5, 6 and 7 obligations mapped to CPS evidence](/artifacts/eu/digital-markets-act/core-obligations-by-obligation.md): 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. - [DMA compliance program and monitoring for gatekeepers](/artifacts/eu/digital-markets-act/compliance-program-and-monitoring.md): 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. - [DMA Core Platform Service Scoping](/artifacts/eu/digital-markets-act/core-platform-service-scoping-by-service.md): Scope EU Digital Markets Act core platform services by service category, designation evidence, user thresholds, and Form GD service-boundary records. - [DMA core platform services FAQ](/artifacts/eu/digital-markets-act/faq/core-platform-services.md): FAQ on EU Digital Markets Act core platform services: Article 2 service categories, gatekeeper designation evidence, user thresholds, service scoping, and Article 11 reporting. - [DMA CPS Obligation Matrix Workflow: Articles 5, 6, 7 and Article 11 Evidence](/artifacts/eu/digital-markets-act/cps-obligation-matrix-workflow.md): 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. - [DMA designation intake workflow for gatekeeper notifications](/artifacts/eu/digital-markets-act/designation-intake-workflow.md): Build a grounded DMA designation intake record covering core platform service classification, Article 3 thresholds, Form GD evidence, Commission handoff, and Article 11 readiness. - [DMA enforcement, penalties, and remedies: Commission powers and evidence](/artifacts/eu/digital-markets-act/enforcement-penalties-and-remedies.md): EU Digital Markets Act enforcement guide covering Commission non-compliance decisions, DMA fine caps, periodic penalty payments, remedies, interim measures, commitments, and Article 11 evidence. - [DMA Gatekeeper Compliance Checklist for Articles 5, 6, 7 and 11](/artifacts/eu/digital-markets-act/gatekeeper-compliance-checklist.md): A grounded 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. - [DMA Gatekeeper Designation Guide: Article 3 thresholds, Form GD, and Article 11 readiness](/artifacts/eu/digital-markets-act/gatekeeper-designation-guide.md): A grounded 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. - [DMA gatekeeper thresholds: what counts and when to notify](/artifacts/eu/digital-markets-act/faq/gatekeeper-thresholds.md): Standalone FAQ on the EU Digital Markets Act gatekeeper thresholds, Article 3 notification timing, Form GD evidence, and active user-count methodology. - [DMA interoperability requests: Article 7 and Commission guidance](/artifacts/eu/digital-markets-act/faq/interoperability-requests.md): How EU Digital Markets Act interoperability requests work for Article 7 messaging services, Article 6(7) operating-system access, gatekeeper evidence, requester evidence, and security safeguards. - [DMA penalties and fines: caps, triggers, and enforcement evidence](/artifacts/eu/digital-markets-act/penalties-and-fines.md): EU Digital Markets Act penalties guide covering Article 30 fine caps, Article 31 periodic penalty payments, non-compliance decisions, remedies, and evidence records. - [DMA Product Change Review Workflow for Articles 5, 6, 7, 11 and 13](/artifacts/eu/digital-markets-act/product-change-review-workflow.md): Review DMA-relevant product releases for Article 5, Article 6, Article 7, anti-circumvention, Article 11 evidence, and product-owner/legal signoff. - [DMA Self-Preferencing Compliance Examples for Ranking and Display](/artifacts/eu/digital-markets-act/self-preferencing-compliance-examples.md): 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. - [DMA vs Data Act: gatekeeper duties compared with EU data-sharing rules](/artifacts/eu/digital-markets-act/dma-vs-data-act.md): Compare the EU Digital Markets Act and EU Data Act by scope, actors, data access, interoperability, reporting, evidence, and enforcement without merging distinct obligations. - [DMA vs DSA: Digital Markets vs Services Act](/artifacts/eu/digital-markets-act/dma-vs-dsa.md): A grounded comparison of the DMA and DSA focused on gatekeepers, core platform services, DMA obligations, Article 11 reporting, interoperability, data access, and enforcement. - [DMA vs EU competition law: gatekeeper obligations, Article 11 evidence, and enforcement](/artifacts/eu/digital-markets-act/dma-vs-eu-competition-law.md): 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. - 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