DMA gatekeeper designation intake workflow

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.

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.

Once the Article 3 trigger is credible, convert the intake into a filing package. The evidence package should be complete enough for Form GD 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.

Before submission, run a handoff meeting with competition counsel, the filing owner, analytics, finance, product, and compliance. The goal is to confirm that each Form GD claim can be traced to an approved dataset, source, or annex.

The handoff record should also cover what happens if the Commission requests information, issues preliminary views, rejects weak substantiated arguments, opens a market investigation route, or designates the undertaking based on information available to it.

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.