DMA CPS Obligation Matrix Workflow

The DMA matrix should begin with the core platform services listed in the Commission designation materials. Article 3 says the designation decision lists the relevant core platform services, and Article 3(10) ties the Articles 5, 6 and 7 compliance obligation to the listed CPS.

Create one row per listed CPS and record the gatekeeper, case identifier, Article 2 CPS category, product owner, legal owner, engineering owner, evidence owner, and Article 11 annex location. Do not merge separate CPS rows just because the same corporate group owns them.

The matrix should have obligation columns, not a generic compliance status column. Articles 5 and 6 each state that the gatekeeper must comply with the obligations in that Article with respect to each listed CPS, but the Article 11 template also expects a reasoned explanation where a specific obligation cannot by nature apply to the relevant CPS.

For every service-and-obligation cell, record applicability separately from delivery status. Use applicable or cannot by nature apply with a cited reason for scope; use not started, implemented, blocked, or under remediation for delivery. Record specification requests and any Commission suspension, exemption, or limited designation in separate fields with the decision and its scope. A specification request alone does not suspend the obligation.

A policy that says 'compliant' does not complete an obligation cell. The Article 11 template asks for a compliance statement plus an exhaustive explanation, supporting data, internal documents, implementation timing, product and geographic scope, technical changes, user-experience changes, remuneration and terms changes, consultations, testing, indicators, and relevant data.

Treat each Article 5, 6 or 7 cell as a mini evidence package. The evidence should let a reader reconstruct what changed, why the change addresses the obligation, which CPS it covers, and how effectiveness is monitored.

Reopen the matrix when the legal designation changes, the product changes, or the evidence no longer demonstrates effective compliance. Article 4 allows the Commission to reconsider, amend, or repeal a designation decision, and the Commission's gatekeeper portal records additions and removals from the designated service list.

Review gates should be concrete enough for product and compliance teams to operate without waiting for an annual reporting cycle.