DMA Interoperability Articles 6(7) and 7

Article 6(7) is the product and platform-feature obligation. It applies where the designated core platform service includes an operating system or virtual assistant and the gatekeeper's own services or hardware access or control hardware or software features that third-party service or hardware providers need for interoperability.

Article 7 is narrower but more process-heavy. It applies where a designated gatekeeper provides a number-independent interpersonal communications service, and another provider offering or intending to offer such a service in the Union requests interoperability for the listed basic functionalities.

An Article 6(7) request should be anchored to a concrete feature, not to a broad desire for platform access. The DMA compares third-party access with the same hardware and software features that are accessed or controlled through the gatekeeper's listed operating system or virtual assistant and are available to the gatekeeper's own services or hardware.

For connected-device and app integrations, the useful evidence is technical: the feature requested, the gatekeeper-controlled interface or operating-system functionality, the third-party use case, the equivalent gatekeeper use, the proposed interoperability route, and any stated integrity, security, or privacy limitation.

Article 7 requires a gatekeeper that provides a listed number-independent interpersonal communications service to make basic functionalities interoperable by providing technical interfaces or similar solutions, upon request and free of charge.

The gatekeeper must publish a reference offer with technical details, general terms and conditions, and necessary details on security and end-to-end encryption. After that publication, another provider offering or intending to offer such services in the Union may request some or all listed basic functionalities, and the gatekeeper must comply with a reasonable request within three months by making the requested basic functionalities operational.

Both interoperability tracks allow security-related controls, but neither permits unsupported product discretion. Article 6(7) allows strictly necessary and proportionate measures to protect the integrity of the gatekeeper's operating system, virtual assistant, hardware, or software features, if duly justified. Article 7 similarly allows strictly necessary and proportionate measures to protect integrity, security, and privacy of messaging services.

A grounded review file should therefore show the requested access, the risk being controlled, the less-restrictive alternatives considered, the technical test results, and why the selected condition does not defeat effective interoperability.

A useful Article 6(7) or Article 7 review does not end when a request form is submitted. The implementation record should prove that the correct DMA track was chosen, the request was handled through the right public or gatekeeper process, and the resulting access works in practice without extra friction that undermines equivalence.

For gatekeepers, the same record feeds Article 11 compliance reporting. For business users and third-party providers, it supports escalation, follow-up questions, and product planning when the gatekeeper's process, documentation, tracker, or decision is incomplete.