EU Digital Markets Act deadlines and compliance calendar

The core DMA deadline chain starts when an undertaking providing core platform services meets the Article 3(2) thresholds. The undertaking must notify the Commission without delay and in any event within 2 months after those thresholds are met.

The Commission designates an undertaking as a gatekeeper without undue delay and at the latest within 45 working days after receiving complete information. Once a core platform service is listed in the designation decision, the gatekeeper has 6 months to comply with Articles 5, 6 and 7 for that listed service.

DMA timing also includes concentration and audit duties. A gatekeeper must inform the Commission of any intended concentration that meets Article 14's scope before implementation and, within 2 months of implementing a concentration, notify additional core platform services that meet Article 3(2)(b). Within 6 months after designation, a gatekeeper must submit the Article 15 audited description of profiling techniques for consumers and then update that description and the public overview at least annually.

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 is the practical hand-off from legal assessment to implementation. For each listed core platform service, create a six-month workback that maps every applicable Article 5, 6 and 7 obligation to a product owner, engineering owner, policy owner, evidence owner, and release date.

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 reporting calendar. The first compliance report is due within 6 months after designation, together with a non-confidential summary. After that, the gatekeeper must update the report at least annually.

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. This makes the annual update a change-control exercise, not just a republication task.

Preparation should begin before a formal designation decision if a core platform service may meet the Article 3 thresholds. The most useful pre-clock work is not generic policy drafting; it is maintaining threshold calculations, service delineations, implementation owner maps, and evidence that can survive Form GD and Article 11 review.

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.