EU Digital Markets Act deadlines and compliance calendar

The core deadline chain begins when an undertaking providing core platform services meets all three presumptive thresholds in Article 3(2). The size limb requires annual Union turnover of at least EUR 7.5 billion in each of the last three financial years or average market capitalisation or equivalent fair market value of at least EUR 75 billion in the last financial year, plus the same core platform service in at least three Member States. The gateway limb requires at least 45 million monthly active end users established or located in the Union and at least 10,000 yearly active business users established in the Union in the last financial year. The durability limb requires those user thresholds in each of the last three financial years.

Meeting all three presumptive thresholds starts notification without delay and no later than 2 months after they are met. It does not create gatekeeper status by itself. A threshold-meeting undertaking may submit sufficiently substantiated Article 3(5) arguments, and the Commission may designate an undertaking that does not meet every quantitative threshold after an Article 17 market investigation based on the qualitative Article 3(1) test.

The Commission must designate a threshold-meeting undertaking without undue delay and no later than 45 working days after receiving the complete Article 3(3) information. A sufficiently substantiated Article 3(5) rebuttal can instead lead to the Article 17 procedure. Once the designation decision lists a core platform service, Article 3(10) gives the gatekeeper 6 months to comply with Articles 5, 6 and 7 for that service.

Article 11 and Article 15 use the gatekeeper's designation date, while Article 3(10) uses the date a service is listed. Article 11 requires the initial compliance report and non-confidential summary within 6 months after designation and updates at least annually. Article 15 requires the independently audited description of consumer-profiling techniques within 6 months after designation, publication of an overview, and updates to both at least annually.

Article 14 has two different concentration triggers. The gatekeeper must inform the Commission of a covered intended concentration after the agreement, public-bid announcement, or acquisition of control and before implementation. If, following the concentration, additional core platform services individually meet the Article 3(2)(b) user thresholds, the gatekeeper must provide the Article 3(2) information within 2 months after implementation.

Use one calendar row per core platform service, including plausible alternative service delineations. The notification workstream should be complete enough for the Commission to assess thresholds, and it should preserve a clean record of estimates, assumptions, supporting documents, and any substantiated Article 3(5) arguments.

The implementing regulation matters for dates because an incomplete notification can delay the effective date of the submission. If material facts change or new information appears while the notification is under review, the undertaking must communicate it without undue delay.

The designation decision fixes the legal scope for implementation. For each listed core platform service, create a six-month workback that maps each applicable Article 5, 6 and 7 obligation to a product owner, engineering owner, policy owner, evidence owner, and release date. Do not extend one service's designation to an unlisted product merely because the same group provides it.

Do not treat the six-month date as only a report deadline. Article 3(10) starts the compliance clock for the listed service, and Article 8 requires the gatekeeper to ensure and demonstrate effective compliance with the obligations.

Article 11 creates a recurring gatekeeper reporting calendar. The first compliance report and non-confidential summary are due within 6 months after the undertaking is designated. After that, the gatekeeper must update both at least annually. The regulation does not prescribe a universal calendar date for those updates, so record the undertaking's actual submission cadence and any Commission direction.

The Commission template asks gatekeepers that previously submitted a report to highlight differences from the previous report and summary, for example by submitting a redline version in addition to a clean version. Treat the annual update as a change-control exercise with evidence for each reported change.

Preparation should begin before a formal designation decision if a core platform service may meet the Article 3 thresholds. Maintain threshold calculations, service delineations, implementation owner maps, and evidence that can support Form GD and Article 11 reporting.

For designated gatekeepers, keep a separate watchlist for new or changing core platform services. A further service that meets the thresholds starts its own Article 3 notification calendar, even if other services are already designated.

Keep a separate merger-and-audit watch as well. If a planned concentration falls within Article 14, log the pre-implementation notice and any 2-month follow-up for newly threshold-crossing services. If Article 15 applies, keep the profiling audit evidence and annual update materials ready alongside the Article 11 workstream.