EU Digital Markets Act deadlines and compliance calendar
Start each DMA deadline from its legal trigger. Threshold notification, Commission designation, service compliance, reporting, concentration notices, and profiling audits do not all use the same clock.
Use this calendar to record the trigger, covered undertaking or service, calculation rule, owner, evidence, and reopening event for each deadline.
A DMA deadline is valid only when its trigger and scope are recorded. Meeting all Article 3(2) thresholds starts the undertaking's notification duty; receipt of complete information starts the Commission's 45-working-day designation period; listing a core platform service starts that service's six-month Articles 5 to 7 compliance clock; and designation of the starts the initial Article 11 report and profiling-audit clocks. Concentrations and annual updates use separate triggers. This calendar shows what to record for each one.
1
Section 1
DMA calendar anchors to track
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 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 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 6 months to comply with Articles 5, 6 and 7 for that service.
Article 11 and use the '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 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.
Threshold trigger: if the Article 3(2) thresholds are met, open a 2-month notification deadline and prepare the Form GD evidence pack.
Below-threshold trigger: if the Commission opens an Article 17 qualitative-designation investigation, calendar that proceeding separately. There is no self-notification deadline merely because an internal assessment concludes that the qualitative Article 3(1) conditions may be met.
Further-service trigger: if an already designated has another core platform service meeting the relevant thresholds, open a separate 2-month notification deadline for that service.
Completeness trigger: treat the 45-working-day Commission designation clock as running from complete information, not from a materially incomplete submission.
Designation trigger: when the decision lists a core platform service, open the 6-month implementation clock for Articles 5, 6 and 7.
Reporting trigger: the 's designation starts the initial Article 11 deadline. A later service listing starts that service's Article 3(10) compliance clock; keep the Article 11 report aligned with the listed services and follow any decision-specific reporting requirement.
Concentration trigger: if a plans a concentration where the merging entities or target provide core platform services, other digital-sector services, or enable data collection, record the Article 14 notice before implementation, even if ordinary EU or national merger-notification thresholds are not met. Monitor the 2-month follow-up deadline for any newly threshold-crossing core platform services.
Profiling audit trigger: within 6 months after designation, calendar the audited description of techniques for profiling of consumers and the annual update of that description and overview.
Status-review trigger: track Commission changes to the list. Article 4 allows the Commission to reconsider a designation at any time, requires review at least every 3 years, and says those reviews do not suspend the gatekeeper's obligations.
Supports checking the current public list of designated gatekeepers and core platform services before setting calendar rows.
23 core platform services provided by those gatekeepers are currently designated
2
Section 2
Calendar rows for notification and designation
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.
Row title: core platform service, service delineation, and whether the undertaking is already designated for another service.
Clock start: date the Article 3(2) thresholds were met or date the further core platform service satisfied the relevant thresholds.
Deadline rule: notification without delay and in any event within 2 months after the threshold trigger.
Submission package: Form GD, threshold data, supporting documents, authorised signatory proof, and separate annexes for Article 3(5) substantiated arguments if used.
Completeness control: record Commission requests for missing information and the date complete information was received or no longer required.
Designation target: from complete information for the standard Article 3(4) decision. Do not use that period for an Article 17 market investigation or another procedure with its own timetable.
Supports the practical instruction that potential gatekeepers use Form GD and the Commission submission channels described on the DMA legislation page.
notification form which potential gatekeepers have to use
3
Section 3
Six-month obligation workback after designation
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 to ensure and demonstrate effective compliance with the obligations.
At designation: freeze the designation decision, listed services, applicable Article 5, 6 and 7 obligations, and any obligation-specific non-applicability rationale.
Before implementation: define service scope, affected user journeys, business-user flows, data flows, APIs, ranking systems, ads systems, consent prompts, and contractual terms that may need changes.
Design approval: approve implementation designs, security and privacy constraints, testing plans, user or business-user consultation plans, and evidence requirements.
Implementation record: collect dated proof of product, technical, policy, and terms changes for each obligation.
Effectiveness check: test using indicators appropriate to the measure, such as consent rates, choice-screen interaction, access requests, switch counts, or business-user feedback where relevant.
Report closeout: prepare the Article 11 report annexes and non-confidential summary so the reporting package matches the measures actually implemented by the six-month deadline.
Supports practical evidence fields for implementation dates, product scope, geographic scope, technical changes, customer-experience changes, testing, feedback, indicators, and raw data readiness.
minimum information that gatekeepers should provide
4
Section 4
Article 11 reporting cadence
Article 11 creates a recurring 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.
Initial due date: designation date plus 6 months for the Article 11 compliance report and non-confidential summary.
Annual cadence: set a report anniversary and an internal workback for evidence refresh, redline review, confidentiality review, and approval.
Required structure: separate and standalone annexes for each designated core platform service, covering each applicable Article 5, 6 and 7 obligation.
Compliance statement: include the undertaking's confirmation as of a specific date for each obligation and explain how the measure ensures compliance.
Evidence refresh: update implementation dates, technical changes, user-interface changes, market testing, consultation, feedback, indicators, and data-access procedures where they changed.
Format control: provide the compliance report, annexes, non-confidential summary, and underlying data in machine-readable form with searchable and recognisable text.
Supports the Article 11 report structure, redline expectation for updated reports, machine-readable format, and detailed compliance evidence fields.
highlight in the latest version
5
Section 5
Preparation tasks before the clock starts
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 applies, keep the profiling audit evidence and annual update materials ready alongside the Article 11 workstream.
Maintain monthly and yearly active-user calculations for each core platform service and each plausible alternative delineation.
Keep the financial-threshold evidence pack current for Union turnover, market capitalisation or equivalent fair market value, and Member State service presence.
Pre-assign owners for Form GD, Article 3(5) arguments, business-secret marking, power of attorney, technical annexes, and submission-channel logistics.
Create an obligation matrix for Articles 5, 6 and 7 before designation so product and engineering teams can start feasibility analysis without waiting for the final report period.
Store evidence in report-ready form: dated implementation records, screenshots or demos where user journeys change, API documentation, access procedures, data-retention explanations, testing methodology, feedback logs, and raw data definitions.
Review the Commission page and case list whenever a designation, amendment, or repeal is announced, then update the calendar row for the affected undertaking and core platform service.
Supports maintaining Form GD threshold data, plausible alternative delineations, substantiated-argument annexes, and submission evidence before notification.
Procedural source for Form GD, notification content, effective-date rules for incomplete submissions, material-change handling, format, language, and authorisation requirements.
Supports Form GD content, completeness rules, effective-date treatment, language, authorisation, confidentiality, and material-change handling for notification submissions.
Supports maintaining Form GD threshold data, plausible alternative delineations, substantiated-argument annexes, and submission evidence before notification.
"the notification or submission shall become effective"
Commission template source for the Article 11 report structure, six-month first report expectation, annual updates, redline practice, machine-readable format, and evidence fields.
Supports practical evidence fields for implementation dates, product scope, geographic scope, technical changes, customer-experience changes, testing, feedback, indicators, and raw data readiness.
Supports the Article 11 report structure, redline expectation for updated reports, machine-readable format, and detailed compliance evidence fields.
"within 6 months after its designation"
More quoted passages
"minimum information that gatekeepers should provide"
Supports the practical instruction that potential gatekeepers use Form GD and the Commission submission channels described on the DMA legislation page.
"notification form which potential gatekeepers have to use"