Artifact GuideEU

DMA Interoperability Articles 6(7) and 7

This page helps separate the DMA's two main interoperability 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 interoperability 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
Jul 24, 2026
Sections
5

Structured answer sets in this page tree.

Primary sources
5

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 24, 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; group text messaging 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; group text messaging 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.

An official source 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 .

  • 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. Article 6(7) is tied to features accessed or controlled through the designated operating system or virtual assistant and available to, or used by, the gatekeeper's own services or hardware. The request still needs a concrete purpose, and the gatekeeper may justify strictly necessary and proportionate integrity measures.

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

digital-markets-act.ec.europa.eu
Referenced sections
  • 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"
digital-markets-act.ec.europa.eu
Referenced sections
  • Commission page points businesses to gatekeeper resources for operating-system interoperability requests, documentation, and request-status information.
"resources for businesses"
eur-lex.europa.eu
Referenced sections
  • DMA text supplies the controlling Article 6(7) and Article 7 conditions for classification, requests, and implementation review.
"upon request, and free of charge"
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