We use privacy-by-default, cookieless analytics.

Optional analytics cookies are used only if you accept them.

Read our Terms of Use and Privacy Policy.

WorkflowEU DMA

DMA gatekeeper designation intake workflow

Review this workflow before a DMA gatekeeper notification to classify each candidate core platform service, test Article 3 thresholds, assemble evidence, and prepare the Commission handoff.

Designed for competition counsel, regulatory operations, finance, analytics, product owners, and compliance teams that need one evidence record before filing or escalation.

Back to main artifactReview sources
Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
5 sections6 primary sources
Overview

Open a DMA designation intake when an undertaking may meet all Article 3(2) thresholds for a core platform service, when an already designated gatekeeper has a further service that may meet the relevant user thresholds, or when facts could support a . Separate each service, preserve the calculations and source data, record any , and prepare the handoff. The Commission, not the undertaking, makes the designation decision.

Section 1

1. Open one intake row per candidate core platform service

Start by classifying the service against the DMA's closed list of core platform service categories. The intake should not treat a platform group, brand, app bundle, or business unit as one undifferentiated service if the DMA analysis depends on the service category and user calculation.

Record the service name, legal undertaking, product owner, business model, Member States where the service is provided, and whether the same service is provided in at least three Member States for the Article 3(2)(a) presumption.

  • Classify the candidate service as online intermediation, search, social networking, video-sharing, number-independent interpersonal communications, operating system, web browser, virtual assistant, cloud computing, or qualifying online advertising service.
  • For integrated services, record why they are one service or distinct services; the DMA Annex warns against splitting services mainly by domain names or geographic attributes.
  • Capture product and analytics contacts who can explain user counts, logged-in and logged-out usage, business accounts, duplicate handling, and outlier months.
  • Check the Commission's public gatekeeper page only as a status reference for existing designations; do not use it as a substitute for the undertaking's own Article 3 intake.
Section 2

2. Test Article 3 designation triggers before drafting Form GD

The intake should show whether the undertaking meets the DMA Article 3(1) gatekeeper requirements directly or is presumed to meet them under Article 3(2). Keep the legal test and the data calculation separate so reviewers can see exactly which fact supports each limb.

If all quantitative thresholds are met, Article 3(3) requires notification to the Commission without delay and in any event within two months after the thresholds are met. The same two-month intake trigger applies when a further core platform service of an already designated gatekeeper meets the relevant user thresholds.

  • Internal-market impact: 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.
  • Gateway scale: 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.
  • Entrenched position: the Article 3(2)(b) user thresholds were met in each of the last three financial years.
  • Qualitative path: if the quantitative thresholds are not all met, preserve facts relevant to Article 3(8), including users, network effects, data-driven advantages, scale and scope effects, lock-in, vertical integration, and other structural service characteristics.
  • Exceptional arguments: if the undertaking meets all quantitative thresholds but argues that Article 3(1) is not satisfied, prepare the substantiated arguments as a separate annex rather than mixing them into the threshold worksheet.
Section 3

3. Build the Form GD evidence intake package

Once the Article 3 trigger is credible, convert the intake into a filing package. The evidence package should be complete enough for review but still traceable back to the service-level intake rows.

Assign one owner for each evidence class: corporate and finance data, service classification, user measurement, business-user methodology, territory coverage, exceptional arguments, signatures, confidentiality, and Commission communications.

  • Corporate evidence: undertaking identity, group structure, contact details, legal representatives, and power of attorney where external representatives are used.
  • Financial evidence: Union turnover for the relevant financial years, market capitalisation or fair market value analysis, and the source systems or public filings used for each figure.
  • Service evidence: description of each candidate core platform service, category rationale, Member State coverage, service boundaries, and integration with other services.
  • User-count evidence: monthly active end users, yearly active business users, unique-user methodology, logged-in and logged-out measurement approach, duplicate controls, and treatment of outlier figures.
  • Argument evidence: a separate annex for any Article 3(5) arguments that the undertaking does not satisfy Article 3(1) despite meeting Article 3(2) thresholds.
  • Submission readiness: confirm the permitted EU official language, required format, page-limit handling, confidentiality claims, and a named Commission communication owner. Article 11(2) of Implementing Regulation (EU) 2023/814 requires digitally transmitted documents to be signed using at least one qualified electronic signature. The Commission's practical page expressly applies this to and the power of attorney. Check the current transmission and signature specifications when assembling the submission package; that practical page does not exempt other documents from Article 11(2).
Section 4

4. Hand the designation package to Commission-facing owners

Before submission, competition counsel, the filing owner, analytics, finance, product, and compliance should confirm that each claim can be traced to an approved dataset, source, or annex.

The handoff record should also cover Commission information requests, preliminary views, rejection of arguments that are not sufficiently substantiated, a possible market investigation, and designation on the basis of available facts where the Regulation permits it.

  • Handoff packet: final service list, threshold worksheet, methodology note, evidence index, confidentiality log, signatory list, power-of-attorney status, and Commission contact owner.
  • Completeness check: each service meeting Article 3(2)(b) has its own user-count support and each exceptional argument has an annex owner.
  • Timing check: the record identifies when the thresholds were met and whether the Article 3(3) two-month notification window has been triggered.
  • Response readiness: keep owners available for Commission information requests, corrections to incomplete data, and observations on preliminary views.
  • Decision capture: when a designation decision is adopted, record the undertaking, each listed core platform service, designation scope, and the date from which Article 3(10) compliance planning is measured.
Section 5

5. Prepare Article 11 readiness as soon as designation risk is real

Designation intake should not end at filing. Article 3(10) gives designated gatekeepers six months after a core platform service is listed in a designation decision to comply with Articles 5, 6, and 7, and Article 11 requires a compliance report within six months after designation plus at least annual updates.

Use the intake to open an Article 11 readiness backlog for every service likely to be listed. The backlog should connect each DMA obligation to product measures, implementation dates, geographic scope, supporting data, internal documents, metrics, privacy or security justifications, and a non-confidential summary track.

  • Create one Article 11 planning row per core platform service and per applicable Article 5, 6, or 7 obligation.
  • Record whether each compliance measure was already in place before designation or needs post-designation implementation.
  • Collect evidence for product, service, device, and geographic scope; technical and engineering changes; APIs or operating-system functionality where relevant; internal data policies; security measures; and metrics used to assess effectiveness.
  • Keep the full methodology for any analysis, testing, or survey that will support the compliance report.
  • Track non-confidential summary drafting in parallel so confidential information decisions do not delay the public-facing summary required by the Commission template.
Recommended next step

Prepare the service-level evidence before filing

Use the workflow to connect each threshold conclusion and service boundary to the dataset, methodology, owner, and Form GD field that supports it.

Research workflow
Open Research Copilot for DMA designation

Check Article 3 thresholds, Form GD fields, service boundaries, and post-designation timing against the cited DMA sources.

Explore next step
Talk to Sorena
Talk through DMA designation intake

Review a candidate service list, evidence gaps, Form GD handoff, and post-designation readiness plan with Sorena.

Explore next step
Primary sources

References and citations

Regulation (EU) 2022/1925 (Digital Markets Act)
eur-lex.europa.eu6 citations
Referenced sections
  • Primary legal source for DMA core platform service categories, Article 3 designation criteria, thresholds, notification timing, Commission designation decisions, and Article 11 readiness triggers.
  • Article 2 lists the core platform service categories and Article 3 links designation to the specific services listed in the designation decision.
  • Article 3 provides the gatekeeper requirements, quantitative presumptions, two-month notification trigger, Commission designation timing, qualitative assessment route, and service-listing effect.
Show 3 more
  • The DMA Annex provides the methodology context for active end-user and active business-user calculations used in Article 3 threshold evidence.
  • Article 3 explains the Commission's 45-working-day designation period after complete information, designation based on available information, and listing of relevant core platform services.
  • Article 3(10) links designation to the six-month compliance period for Articles 5, 6, and 7; Article 11 establishes the compliance-report obligation.
"Designation of gatekeepers"
More quoted passages
"‘core platform service’ means any of the following"
"without delay and in any event within 2 months"
"active end users and active business users"
"at the latest within 45 working days"
"within 6 months after a core platform service"
Commission Implementing Regulation (EU) 2023/814 - Form GD
eur-lex.europa.eu4 citations
Referenced sections
  • Source for the Form GD notification procedure, required notification contents, substantiated-argument annex, format and length rules, and procedural communication requirements.
  • Article 2 requires Article 3(3) notifications to contain the information and documents indicated in Form GD, including any Article 3(5) substantiated arguments in an annex.
  • This implementing regulation sets the Form GD notification framework, effective-date rules, format requirements, and annex route for Article 3(5) arguments.
Show 1 more
  • This source supports handoff controls for notifications, submissions, effective dates, format and length rules, and communication with the Commission.
"FORM RELATING TO THE NOTIFICATION"
More quoted passages
"Notifications pursuant to Article 3(3)"
"detailed arrangements for the conduct of certain proceedings"
European Commission - DMA gatekeepers page
digital-markets-act.ec.europa.eu2 citations
Referenced sections
  • Commission public status page for checking current gatekeeper and core platform service designations after an internal intake has identified a relevant undertaking or service.
  • This public Commission page to verify whether an undertaking or service is already listed is designated, amended, or repealed.
"Gatekeepers"
European Commission - DMA practical information
digital-markets-act.ec.europa.eu2 citations
Referenced sections
  • Commission practical page for submission format, language, templates, power of attorney support, and QES signature expectations for Form GD and related documents.
  • Commission practical information confirms submission formatting, language expectations, and that Form GD and power of attorney documents sent digitally need a qualified electronic signature.
"Signing documents electronically"
More quoted passages
"notifications (Form GD) and the Power of Attorney"
European Commission - Article 11 DMA compliance report template
digital-markets-act.ec.europa.eu
Referenced sections
  • The Commission template explains the minimum information expected in Article 11 compliance reports, including service-by-service annexes, supporting data, internal documents, and non-confidential summaries.
"TEMPLATE FORM FOR REPORTING PURSUANT TO ARTICLE 11"
European Commission - DMA legislation and templates
digital-markets-act.ec.europa.eu
Referenced sections
  • Commission page that hosts DMA procedural materials and templates, including the Article 11 compliance report template used for post-designation readiness planning.
"Article 11 DMA - Compliance Report Template Form"

Related guides

DMA Anti-Circumvention Design Review for Gatekeeper Product Changes

Review DMA Article 13 anti-circumvention risks in gatekeeper product, interface, contractual, commercial, and technical changes with obligation mapping and evidence records.

DMA Article 6 Business User Data Access Guide

Official source guide to EU Digital Markets Act Article 6 data access for business users, end users, authorised third parties, consent boundaries, and evidence handoffs.

DMA Article 6(7) and Article 7 interoperability obligations

Official source guide to DMA interoperability duties: Article 6(7) operating-system feature access, Article 7 messaging interoperability, request handling, security conditions, and compliance evidence.

DMA Articles 5, 6 and 7 obligations mapped to CPS evidence

Map EU Digital Markets Act Articles 5, 6 and 7 obligations to affected core platform services, product evidence, legal owners, and Article 11 compliance-report artifacts.

DMA compliance program and monitoring for gatekeepers

Build a DMA compliance program around Article 8 effective compliance, Article 11 reporting evidence, Article 13 anti-circumvention controls, and Article 28 compliance-function governance.

DMA Core Platform Service Scoping

Scope EU Digital Markets Act core platform services by service category, designation evidence, user thresholds, and Form GD service-boundary records.

Show all related guides (32)

DMA CPS Obligation Matrix Workflow: Articles 5, 6, 7 and Article 11 Evidence

Build a DMA core platform service obligation matrix that links each designated CPS to Articles 5, 6 and 7 duties, product owners, designation evidence, Article 11 report artifacts and review gates.

DMA enforcement, penalties, and remedies: Commission powers and evidence

Follow DMA enforcement from investigation and preliminary findings to non-compliance decisions, fines, daily payments, interim measures, commitments, and remedies.

DMA Gatekeeper Compliance Checklist for Articles 5, 6, 7 and 11

A cited EU Digital Markets Act checklist for designated gatekeepers: core platform service scope, Article 5/6/7 controls, Article 11 report evidence, anti-circumvention checks, and review gates.

DMA Gatekeeper Designation Guide: Article 3 thresholds, Form GD, and Article 11 readiness

A cited EU Digital Markets Act guide for assessing Article 3 gatekeeper thresholds, scoping core platform services, preparing Form GD evidence, handling rebuttal annexes, and planning Article 11 compliance reporting.

DMA penalties and fines: caps, triggers, and enforcement evidence

Compare DMA Article 30 fine ceilings, the narrow 20% repeat test, 1% procedural fines, and Article 31 daily payments, with decision-specific examples.

DMA Product Change Review Workflow for Articles 5, 6, 7, 11 and 13

Review DMA-relevant product releases for Article 5, Article 6, Article 7, anti-circumvention, Article 11 evidence, and product-owner/legal signoff.

DMA Self-Preferencing Compliance Examples for Ranking and Display

Examples and release-review controls for DMA Article 6(5) self-preferencing checks across ranking, indexing, crawling, search results, marketplaces, app stores, feeds, and virtual assistants.

DMA vs Data Act: gatekeeper duties compared with EU data-sharing rules

Compare the EU Digital Markets Act and EU Data Act by scope, actors, data access, interoperability, reporting, evidence, and enforcement without merging distinct obligations.

DMA vs DSA: Digital Markets vs Services Act

Compare the EU Digital Markets Act and Digital Services Act by covered services, regulated actors, core duties, reporting, dates, evidence, and enforcement.

DMA vs EU competition law: gatekeeper obligations, Article 11 evidence, and enforcement

Compare the EU Digital Markets Act with EU competition law: ex ante gatekeeper and core platform service duties, Articles 5 to 7, Article 11 reports, penalties, and evidence records.

DMA vs GDPR: gatekeeper data obligations compared

Compare DMA gatekeeper duties with GDPR rules for personal-data processing, consent, lawful basis, portability, accountability evidence, and enforcement.

EU Digital Markets Act Article 11 Evidence Calendar

Build a DMA Article 11 compliance-report calendar with the correct designation trigger, service annexes, evidence owners, annual updates, and publication gates.

EU Digital Markets Act checklist for gatekeeper compliance

A source-grounded Sorena DMA checklist for designated gatekeepers and core platform services, covering scope, Articles 5, 6 and 7 obligations, Article 11 reporting, evidence, anti-circumvention, and governance.

EU Digital Markets Act compliance: gatekeeper obligations and evidence

DMA compliance guide for designated gatekeepers: core platform service scoping, Articles 5, 6 and 7 controls, Article 11 reports, anti-circumvention checks, interoperability evidence, and enforcement risk.

EU Digital Markets Act deadlines and compliance calendar

Calculate DMA notification, designation, service-compliance, Article 11 reporting, concentration-notice, and profiling-audit deadlines from the correct legal trigger.

EU Digital Markets Act FAQ: gatekeepers, DMA obligations, reports, and enforcement

Concise FAQ on the EU Digital Markets Act for gatekeeper designation, core platform services, Articles 5, 6 and 7 obligations, Article 11 reports, interoperability, business-user data access, compliance evidence, and enforcement.

EU Digital Markets Act requirements for gatekeepers

DMA requirements for designated gatekeepers: core platform service scope, Articles 5, 6 and 7 obligations, Article 11 reporting, anti-circumvention, evidence, remedies, and fines.

EU Digital Markets Act timeline: application, designation, reporting, and review

DMA timeline separating fixed legal dates, threshold and designation clocks, recurring reports, service-specific decisions, final enforcement, and the first Article 53 review.

EU DMA Applicability Test: gatekeeper thresholds, core platform services, and evidence

Test whether the EU Digital Markets Act may apply to a platform service using the DMA gatekeeper criteria, core platform service categories, EU user thresholds, notification steps, and evidence records.

EU DMA Article 11 Compliance Reporting Guide

Official source guide to EU Digital Markets Act Article 11 compliance reports: report purpose, template evidence, non-confidential summaries, annual updates, and submission steps.

EU DMA do's and don'ts for product teams

Product release checks for designated DMA gatekeepers: Article 5, 6 and 7 obligations, anti-circumvention review, data access, interoperability, self-preferencing and Article 11 evidence.

DMA Article 11 Compliance Report Template FAQ

How gatekeepers should use the DMA Article 11 compliance report template to document obligation-by-obligation measures, evidence, updates, and non-confidential summaries.

DMA core platform services FAQ

FAQ on EU Digital Markets Act core platform services: Article 2 service categories, gatekeeper designation evidence, user thresholds, service scoping, and Article 11 reporting.

DMA gatekeeper thresholds: what counts and when to notify

Standalone FAQ on the EU Digital Markets Act gatekeeper thresholds, Article 3 notification timing, Form GD evidence, and active user-count methodology.

DMA interoperability requests: Article 7 and Commission guidance

How DMA Article 7 messaging interoperability requests work, including phased functions, the three-month operational deadline, reference offers, evidence, and safeguards.

What do DMA Articles 5, 6, and 7 require from gatekeepers?

FAQ explaining how EU Digital Markets Act Articles 5, 6, and 7 group gatekeeper obligations, what product evidence they require, and how Article 11 reporting connects.