Artifact GuideEU

DMA Interoperability Articles 6(7) and 7

This page helps separate the DMA's two main tracks: Article 6(7) access to gatekeeper hardware and software features, and Article 7 interoperability for number-independent interpersonal communications services.

Based on the DMA text, Commission Q&A, resources for businesses, and Commission compliance-report expectations for technical, security, privacy, and evidence records.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

The DMA has two distinct duties. requires a designated gatekeeper to provide free and effective access to certain hardware, software, operating-system, and virtual-assistant features made available to the gatekeeper's own services or hardware. Article 7 governs number-independent interpersonal communications services and includes reference offers, reasonable interoperability requests, security preservation, and strict limits on personal-data exchange.

Section 1

Separate Article 6(7) feature access from Article 7 messaging interoperability

Article 6(7) has two limbs. The first requires providers of services and hardware to receive access for to the same hardware and software features controlled through a listed operating system or virtual assistant and available to the gatekeeper's own services or hardware. The second requires access for business users and alternative providers of services provided together with or in support of core platform services to the same operating-system, hardware, or software features available to or used by the gatekeeper for those services, whether or not the features are part of the operating system.

Article 7 is narrower but has its own staged timetable and request process. It applies only where a number-independent interpersonal communications service is listed in the gatekeeper's designation decision. A provider offering or intending to offer such a service in the Union may request some or all of the basic functionalities listed in Article 7(2).

  • Use Article 6(7) for operating-system, virtual-assistant, hardware, and software feature access needed by service providers, hardware providers, business users, or alternative providers.
  • Use Article 7 for messaging-service : one-to-one text and attached-file sharing following listing and within the general six-month Article 3(10) compliance period; text messaging within groups and attached-file sharing between a group chat and an individual end user within two years of designation; and voice and video calls between two individual end users and between a group chat and an individual end user within four years of designation, provided the gatekeeper offers the functionality to its own end users.
  • Do not treat a developer API, device pairing feature, data portability request, advertising measurement request, and messaging request as the same queue.
  • Record the designated gatekeeper, designated core platform service, requested feature or functionality, requesting party, free-of-charge access point, and security or integrity condition.
Section 2

Article 6(7): what a request should identify

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 route, and any stated integrity, security, or privacy limitation.

Commission specification decisions can make this comparison concrete. On 16 July 2026, the Commission adopted binding measures for Alphabet covering between third-party AI services and 11 Google Android features. The Commission states that most measures are due in Android 18 and by 1 August 2027, while concurrent hotword detection is due in Android 19 and by 1 August 2028. Those dates belong to that decision, not to every Article 6(7) request.

  • Name the feature or capability: for example notifications, pairing, local connectivity, file transfer, media casting, NFC reader/writer use, background execution, or automatic audio/Wi-Fi behavior when those are based on the Commission's Apple materials.
  • Identify whether the requester is a provider of services, provider of hardware, business user, or alternative provider of services supplied with or in support of a core platform service.
  • Check whether the gatekeeper has made guidance, API documentation, request forms, trackers, or contact points available for the relevant operating system.
  • Keep the gatekeeper's reason for any refusal, delay, or security condition alongside the technical test evidence, because Article 6(7) permits only strictly necessary and proportionate integrity measures that are duly justified.
Section 3

Article 7: reference offers, reasonable requests, and user choice

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 within the six-month period in Article 3(10), updating it where necessary. After publication, another provider offering or intending to offer such services in the Union may request some or all listed basic functionalities. The gatekeeper must comply with a reasonable request within three months by making the requested functionalities operational.

The Commission may exceptionally extend an Article 7(2) or 7(5) deadline after a reasoned gatekeeper request, but only where the gatekeeper demonstrates that an extension is necessary for effective and the required security level.

  • Check whether the requester is a provider of number-independent interpersonal communications services in the Union or intending to offer them in the Union.
  • Map the requested functionality to the Article 7 list and applicable date: one-to-one text and attached files following listing and within the Article 3(10) compliance period; text messaging within groups and attached-file sharing between a group chat and an individual end user within two years of designation; and voice and video calls between two individual end users and between a group chat and an individual end user within four years of designation.
  • Store the published reference offer version, technical interface details, general terms, security and encryption statements, request date, reasonableness assessment, and operational readiness evidence.
  • Do not force end users into : Article 7 preserves the freedom of users of both services to decide whether to use interoperable basic functionalities.
Section 4

Security, integrity, privacy, and product-review evidence

Both 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.

The review record 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.

  • Keep architecture notes, API or interface documentation, test results, compatibility findings, abuse-case analysis, and release notes for each measure.
  • For Article 7, preserve evidence that the gatekeeper's own security level, including end-to-end encryption where applicable, is preserved across interoperable services.
  • For personal data exchanged under Article 7, document why each data element is strictly necessary for effective and how GDPR and ePrivacy compliance is handled.
  • When a gatekeeper rejects, delays, narrows, or conditions access, keep the written reason, technical basis, proportionality analysis, reviewer identity, and any appeal, independent review, conciliation, or Commission-facing record.
Section 5

How to review an interoperability implementation before relying on it

A useful Article 6(7) or Article 7 review does not end when a request form is submitted. The implementation record should show that the correct DMA track was chosen, the request used the relevant published process, and the resulting access works in practice. For Article 6(7), compare access with the same features available to or used by the gatekeeper in the circumstances described by that paragraph. For Article 7, test the requested functionality against the reference offer and the applicable deadline.

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.

Close the review only with a recorded outcome: access implemented and tested; conditionally accepted with dated remediation; rejected with the controlling criterion and review route; or outside Article 6(7) and Article 7 with the alternate legal or product process identified. Reopen it when the requested feature, gatekeeper equivalent, reference offer, API, security basis, designation decision, or Commission specification changes.

Does DMA Article 6(7) require every operating-system feature to be opened to every developer?

No. For providers of services and hardware, Article 6(7) covers the same hardware and software features accessed or controlled through the listed operating system or virtual assistant and available to the gatekeeper's own services or hardware. A second limb gives business users and alternative providers of services supplied with or in support of core platform services access to the same operating-system, hardware, or software features available to or used by the gatekeeper for those services, whether or not the features are part of the operating system. In both cases, the gatekeeper may impose duly justified integrity measures that are strictly necessary and proportionate.

What is the key Article 7 evidence for a messaging request?

Keep the gatekeeper's reference offer and version, the requested basic functionalities, the request date, the reasonableness assessment, technical-interface evidence, the three-month operationalisation record, security and encryption analysis, user-choice handling, and the strict-necessity basis for any personal data exchange. Also record whether the functionality was due following listing, within two years, or within four years of designation, and whether the Commission granted an extension.

Does a DMA specification decision mean the Commission found the gatekeeper non-compliant?

No. An Article 8 specification decision sets binding measures intended to achieve effective compliance with an Article 6 or 7 obligation. The Commission's Q&A distinguishes it from a non-compliance decision, which separately determines infringement and can support enforcement measures or fines.

  • Classify the request as Article 6(7), Article 7, or outside these provisions before starting technical work.
  • Attach the public reference offer, resource page, request form, technical reference, tracker entry, or gatekeeper response that controls the workflow.
  • Compare the third-party experience with the gatekeeper's own service or hardware where Article 6(7) equivalence is the issue.
  • For Article 7, verify request reasonableness, three-month operationalisation evidence, security preservation, end-user choice, and strict data minimisation.
  • Record open issues separately: missing documentation, unavailable interfaces, unclear eligibility criteria, rejected requests, non-public confidentiality constraints, or security claims that lack a technical explanation.
Primary sources

References and citations

eur-lex.europa.eu6 citations
Referenced sections
  • Binding DMA text for Article 6(7) feature interoperability, Article 7 messaging interoperability, security, privacy, reference offers, and request handling.
  • Article 6(7) sets the free and effective interoperability duty for gatekeeper-controlled features; Article 7 sets the separate duty for number-independent interpersonal communications services.
  • Article 6(7) defines the feature-access obligation and the gatekeeper's limited integrity justification.
Show 3 more
  • Article 7 provides the reference-offer, reasonable-request, three-month implementation, security, user-choice, and data-minimisation rules for messaging interoperability.
  • Articles 6(7) and 7 set the legal boundaries for integrity, security, privacy, encryption, and strictly necessary data exchange.
  • DMA text supplies the controlling Article 6(7) and Article 7 conditions for classification, requests, and implementation review.
"free of charge, effective interoperability"
More quoted passages
"strictly necessary and proportionate"
"publish a reference offer"
"strictly necessary to provide effective interoperability"
"upon request, and free of charge"
digital-markets-act.ec.europa.eu5 citations
Referenced sections
  • Commission Q&A for Article 6(7) specification decisions on Apple iOS/iPadOS interoperability and process measures.
  • Commission Q&A explains Apple Article 6(7) specification decisions for connected-device features and the request-handling process.
  • Commission Q&A gives examples of iOS features covered by Apple specification decisions and describes the transparency and request-process measures.
Show 2 more
  • Commission Q&A explains that specification decisions can detail secure measures for third-party use of features previously available only to gatekeeper devices or services.
  • Commission Q&A describes the Apple request-process specification decision, including transparency, developer support, feedback, recourse, tracker, and reporting themes.
"Interoperability (Questions and Answers)"
More quoted passages
"Apple 6(7) specifications"
"9 iOS connectivity features"
"securely allow third parties"
"request-based process"
digital-markets-act.ec.europa.eu3 citations
Referenced sections
  • Commission resource page listing business-facing DMA resources, including Article 6(7) operating-system interoperability request resources.
  • Commission resource page lists Article 6(7) operating-system interoperability resources for businesses, including request channels and public request information for relevant gatekeepers.
  • Commission page points businesses to gatekeeper resources for operating-system interoperability requests, documentation, and request-status information.
"Article 6(7)"
More quoted passages
"Interoperability with OS features"
"resources for businesses"
digital-markets-act.ec.europa.eu2 citations
Referenced sections
  • Current Commission source for the 16 July 2026 Google Android Article 6(7) specification decision, covered AI-service features, implementation dates, and monitoring.
  • Supports the 16 July 2026 final decision, the 11 Google Android feature groups, and the decision-specific implementation dates of 1 August 2027 and 1 August 2028.
digital-markets-act.ec.europa.eu2 citations
Referenced sections
  • Commission practical-information page hosting DMA submission materials; the Article 11 template supports compliance evidence expectations for Articles 5 to 7.
  • Commission practical-information page hosts DMA submission materials; the Article 11 template expects technical, engineering, security, API, OS-functionality, indicator, and justification evidence for Articles 5 to 7 compliance.
"Compliance Report Template Form"
Show all related guides (32)

DMA designation intake workflow for gatekeeper notifications

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.

DMA enforcement, penalties, and remedies: Commission powers and evidence

Follow DMA enforcement from investigation and preliminary findings to non-compliance decisions, fines, daily payments, interim measures, commitments, and remedies.

DMA Gatekeeper Compliance Checklist for Articles 5, 6, 7 and 11

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.

DMA Gatekeeper Designation Guide: Article 3 thresholds, Form GD, and Article 11 readiness

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.

DMA penalties and fines: caps, triggers, and enforcement evidence

Compare DMA Article 30 fine ceilings, the narrow 20% repeat test, 1% procedural fines, and Article 31 daily payments, with decision-specific examples.

DMA Product Change Review Workflow for Articles 5, 6, 7, 11 and 13

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

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

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

Compare the EU Digital Markets Act and Digital Services Act by covered services, regulated actors, core duties, reporting, dates, evidence, and enforcement.

DMA vs EU competition law: gatekeeper obligations, Article 11 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.

DMA vs GDPR: gatekeeper data obligations compared

Compare DMA gatekeeper duties with GDPR rules for personal-data processing, consent, lawful basis, portability, accountability evidence, and enforcement.

EU Digital Markets Act Article 11 Evidence Calendar

Build a DMA Article 11 compliance-report calendar with the correct designation trigger, service annexes, evidence owners, annual updates, and publication gates.

EU Digital Markets Act checklist for gatekeeper compliance

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.

EU Digital Markets Act compliance: gatekeeper obligations and evidence

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.

EU Digital Markets Act deadlines and compliance calendar

Calculate DMA notification, designation, service-compliance, Article 11 reporting, concentration-notice, and profiling-audit deadlines from the correct legal trigger.

EU Digital Markets Act FAQ: gatekeepers, DMA obligations, reports, and enforcement

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.

EU Digital Markets Act requirements for gatekeepers

DMA requirements for designated gatekeepers: core platform service scope, Articles 5, 6 and 7 obligations, Article 11 reporting, anti-circumvention, evidence, remedies, and fines.

EU Digital Markets Act timeline: application, designation, reporting, and review

DMA timeline separating fixed legal dates, threshold and designation clocks, recurring reports, service-specific decisions, final enforcement, and the first Article 53 review.

EU DMA Applicability Test: gatekeeper thresholds, core platform services, and evidence

Test whether the EU Digital Markets Act may apply to a platform service using the DMA gatekeeper criteria, core platform service categories, EU user thresholds, notification steps, and evidence records.

EU DMA Article 11 Compliance Reporting Guide

Official source guide to EU Digital Markets Act Article 11 compliance reports: report purpose, template evidence, non-confidential summaries, annual updates, and submission steps.

EU DMA do's and don'ts for product teams

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.

DMA Article 11 Compliance Report Template FAQ

How gatekeepers should use the DMA Article 11 compliance report template to document obligation-by-obligation measures, evidence, updates, and non-confidential summaries.

DMA core platform services FAQ

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 gatekeeper thresholds: what counts and when to notify

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

How DMA Article 7 messaging interoperability requests work, including phased functions, the three-month operational deadline, reference offers, evidence, and safeguards.

What do DMA Articles 5, 6, and 7 require from gatekeepers?

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.