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EU Digital Markets Act (DMA) Deadlines & Compliance Calendar

Turn DMA timelines into calendar entries your teams can execute.

Includes designation deadlines, the 6-month compliance clock, reporting cadence, and Article 7 staged interoperability timelines.

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Author

Sorena AI

Published

Feb 21, 2026

Updated

Feb 23, 2026

Sections

Structured answer sets in this page tree.

Primary sources

Cited legal and guidance references.

Publication metadata

Sorena AI

Published Feb 21, 2026

Updated Feb 23, 2026

Overview

The fastest DMA programs treat legal deadlines as delivery dates. This page converts the EU Digital Markets Act (DMA) timing rules into a practical compliance calendar: when you must notify the Commission, when designation must happen, when obligations must be met, and how to plan for ongoing reporting and staged interoperability.

Section 1

Baseline DMA timeline: application, designation, compliance

The DMA has a general application date and a separate "designation -> compliance" clock that matters most for implementation teams.

Your calendar should track three overlapping timelines: (1) regulation-level milestones, (2) CPS-level designation milestones, and (3) obligation-level delivery milestones.

DMA application date: 2 May 2023 (with some provisions applying earlier, including delegated-act powers starting 1 Nov 2022 and Articles 42 and 43 from 25 Jun 2023).
Notification deadline (threshold-based presumption): notify the Commission without delay and in any event within 2 months after thresholds are met.
Designation decision deadline: the Commission must designate without undue delay and at the latest within 45 working days after receiving complete information.
Compliance deadline: comply with Articles 5, 6, and 7 within 6 months after a CPS is listed in the designation decision.

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Section 2

Calendar template: key entries to create for each CPS

Create a calendar per listed core platform service (CPS). Each CPS can have different designation dates and therefore different compliance due dates.

If you operate multiple CPS categories (e.g., OS + app store + browser + ads), you should expect different owners and evidence packs per CPS.

T0: internal threshold trigger date (when you believe thresholds were met) -> start 2-month notification countdown.
T0 + 2 months: notification deadline for threshold-based presumption cases (Article 3(3)).
T1: "complete information received" date (for Commission) -> start 45 working day designation countdown.
T2: designation decision date (CPS listed) -> start 6-month compliance countdown (Articles 5-7).
T2 + 6 months: Article 5/6/7 compliance due date per CPS; align release trains and evidence capture to this date.

Section 3

Article 11 compliance reporting: plan for evidence early

DMA compliance is expected to be documented. The Commission provides a template for Article 11 compliance reporting and expects detailed, transparent explanations of measures, supported by data and internal documentation.

Treat the compliance report as a product deliverable: it forces you to articulate how you comply per CPS and per obligation, and it is easier to write when evidence is captured as you implement.

Within 6 months after designation: provide a detailed compliance report and a non-confidential summary (Article 11 template guidance).
At least annually: update the compliance report; plan an annual "DMA evidence refresh" sprint.
Machine-readable format expectation: store the report, annexes, non-confidential summary, and underlying data in structured repositories that can be exported without manual reconstruction.
Raw data readiness: the Article 11 template expects the underlying raw data to be ready if the Commission requests it.

Section 4

Article 7 interoperability calendar (staged: 0 / 2 years / 4 years)

If you provide a number-independent interpersonal communications service (NICS) listed in the designation decision, Article 7 introduces staged deadlines relative to the designation date.

These milestones often require protocol work, security assurance, abuse prevention, and operational readiness for interoperability requests.

After listing: 1:1 interoperability for end-to-end text messaging and 1:1 file sharing (where offered to your users).
Within 2 years from designation: group text messaging and group-to-individual file sharing interoperability.
Within 4 years from designation: voice and video calls (1:1 and group-to-individual).
Operational SLA: comply with a reasonable interoperability request within 3 months after receiving the request; publish and maintain a reference offer.

Section 5

Real-world anchor dates (useful for planning cadence)

Use public designation and enforcement dates as "cadence markers" to keep your DMA program current and benchmark your readiness against Commission activity.

These dates do not replace your CPS-specific deadlines - they help you understand when the Commission has acted and how quickly programs may need to adapt.

6 Sep 2023: first Commission designations (examples include Alphabet, Amazon, Apple, ByteDance, Meta, Microsoft).
29 Apr 2024: Apple designated for iPadOS (tablet operating system) as a gatekeeper for that CPS.
13 May 2024: Booking designated for its online intermediation service (Booking.com).
23 Apr 2025: Meta was undesignated for Facebook Marketplace, which shows that CPS status can change over time.
5 Feb 2026: the Commission concluded Apple Ads and Apple Maps should not be designated after Apple notified those services in Nov 2025.
3 May 2026: Commission evaluation and reporting deadline, and subsequently every 3 years.

Section 6

Workstream planning: map deadlines to owners and evidence

A DMA compliance calendar should not just list dates - it should map each date to owners, deliverables, and evidence outcomes.

Use this mapping to drive weekly execution meetings: "What must ship by the next deadline, and what evidence must be captured?"

Obligation owner: assign a product owner and a policy/legal owner for each obligation cluster (data combination, app distribution, ranking, interoperability, ads transparency).
Evidence owner: assign a compliance evidence lead per CPS to ensure report-ready artifacts exist (demos, screenshots, logs, API docs).
Exception register: if you rely on integrity/security constraints, record justification and proportionality analysis with test results and risk assessments.

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