---
title: "DMA Article 6(7) and Article 7 interoperability obligations"
canonical_url: "https://www.sorena.io/artifacts/eu/digital-markets-act/article-6-7-interoperability"
source_url: "https://www.sorena.io/artifacts/eu/digital-markets-act/article-6-7-interoperability"
author: "Sorena AI"
description: "Grounded guide to DMA interoperability duties: Article 6(7) operating-system feature access, Article 7 messaging interoperability, request handling, security conditions, and compliance evidence."
published_at: "2026-05-09"
updated_at: "2026-05-25"
keywords:
  - "Digital Markets Act"
  - "DMA"
  - "Article 6(7)"
  - "Article 7"
  - "interoperability"
  - "gatekeeper"
  - "operating system"
  - "messaging interoperability"
---
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---

# DMA Article 6(7) and Article 7 interoperability obligations

Grounded guide to DMA interoperability duties: Article 6(7) operating-system feature access, Article 7 messaging interoperability, request handling, security conditions, and compliance evidence.

*Artifact Guide* *EU*

## DMA Interoperability Articles 6(7) and 7

Use this page to 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.

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

DMA interoperability is not one generic access duty. Article 6(7) requires a designated gatekeeper to provide free and effective interoperability with certain hardware, software, operating-system, and virtual-assistant features made available to the gatekeeper's own services or hardware. Article 7 separately governs number-independent interpersonal communications services and includes reference offers, reasonable interoperability requests, security preservation, and strict limits on personal-data exchange.

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

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.

- 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 interoperability: one-to-one text, file sharing, group messaging, voice calls, and video calls as the staged basic functionalities become applicable.
- Do not treat a developer API, device pairing feature, data portability request, advertising measurement request, and messaging interoperability 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.

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 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.
- [European Commission - DMA interoperability questions and answers](https://digital-markets-act.ec.europa.eu/questions-and-answers/interoperability_en?ref=sorena.io) - Commission Q&A explains Apple Article 6(7) specification decisions for connected-device features and the request-handling process.

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

- 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 grounded in 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.

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 6(7) defines the feature-access obligation and the gatekeeper's limited integrity justification.
- [European Commission - Resources for businesses](https://digital-markets-act.ec.europa.eu/questions-and-answers/resources-businesses_en?ref=sorena.io) - Commission resource page lists Article 6(7) operating-system interoperability resources for businesses, including request channels and public request information for relevant gatekeepers.
- [European Commission - DMA interoperability questions and answers](https://digital-markets-act.ec.europa.eu/questions-and-answers/interoperability_en?ref=sorena.io) - Commission Q&A gives examples of iOS features covered by Apple specification decisions and describes the transparency and request-process measures.

## 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. 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.

- 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: one-to-one text and file sharing, group messaging and group file sharing, and later voice or video call functionality where applicable.
- 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 interoperability: Article 7 preserves the freedom of users of both services to decide whether to use interoperable basic functionalities.

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 7 provides the reference-offer, reasonable-request, three-month implementation, security, user-choice, and data-minimisation rules for messaging interoperability.

## Security, integrity, privacy, and product-review evidence

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.

- Keep architecture notes, API or interface documentation, test results, compatibility findings, abuse-case analysis, and release notes for each interoperability 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 interoperability 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.

Sources for this answer:

- [Regulation (EU) 2022/1925 (Digital Markets Act)](https://eur-lex.europa.eu/eli/reg/2022/1925/oj?ref=sorena.io) - Articles 6(7) and 7 set the legal boundaries for integrity, security, privacy, encryption, and strictly necessary data exchange.
- [European Commission - Article 11 compliance report materials](https://digital-markets-act.ec.europa.eu/about-dma/practical-information_en?ref=sorena.io) - 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.
- [European Commission - DMA interoperability questions and answers](https://digital-markets-act.ec.europa.eu/questions-and-answers/interoperability_en?ref=sorena.io) - 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.

## 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 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.

- 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.

Sources for this answer:

- [Regulation (EU) 2022/1925 (Digital Markets Act)](https://eur-lex.europa.eu/eli/reg/2022/1925/oj?ref=sorena.io) - DMA text supplies the controlling Article 6(7) and Article 7 conditions for classification, requests, and implementation review.
- [European Commission - Resources for businesses](https://digital-markets-act.ec.europa.eu/questions-and-answers/resources-businesses_en?ref=sorena.io) - Commission page points businesses to gatekeeper resources for operating-system interoperability requests, documentation, and request-status information.
- [European Commission - DMA interoperability questions and answers](https://digital-markets-act.ec.europa.eu/questions-and-answers/interoperability_en?ref=sorena.io) - Commission Q&A describes the Apple request-process specification decision, including transparency, developer support, feedback, recourse, tracker, and reporting themes.

*Recommended next step*

*Placement: before sources*

## Use this guide to classify and evidence Article 6(7) and Article 7 work

Sorena can help map DMA interoperability requests to the correct obligation, cited source, product owner, technical evidence, security review, and follow-up record.

- [Open Research Copilot for DMA](/solutions/research-copilot.md): Ask source-linked questions about Article 6(7), Article 7, interoperability requests, security conditions, and compliance evidence.
- [Review an interoperability workflow](/contact.md): Check whether a request, feature-access process, or messaging interoperability record is grounded in the cited DMA sources.

## Primary sources

- [Regulation (EU) 2022/1925 (Digital Markets Act)](https://eur-lex.europa.eu/eli/reg/2022/1925/oj?ref=sorena.io) - Binding DMA text for Article 6(7) feature interoperability, Article 7 messaging interoperability, security, privacy, reference offers, and request handling.
  - Quote: "free of charge, effective interoperability"
- [European Commission - DMA interoperability questions and answers](https://digital-markets-act.ec.europa.eu/questions-and-answers/interoperability_en?ref=sorena.io) - Commission Q&A for Article 6(7) specification decisions on Apple iOS/iPadOS interoperability and process measures.
  - Quote: "Interoperability (Questions and Answers)"
- [European Commission - Resources for businesses](https://digital-markets-act.ec.europa.eu/questions-and-answers/resources-businesses_en?ref=sorena.io) - Commission resource page listing business-facing DMA resources, including Article 6(7) operating-system interoperability request resources.
  - Quote: "Article 6(7)"
- [European Commission - Article 11 compliance report materials](https://digital-markets-act.ec.europa.eu/about-dma/practical-information_en?ref=sorena.io) - Commission practical-information page hosting DMA submission materials; the Article 11 template supports compliance evidence expectations for Articles 5 to 7.
  - Quote: "Compliance Report Template Form"

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