EU Digital Markets Act Articles 5, 6, and 7 gatekeeper obligations

Article 5 contains direct gatekeeper obligations for the listed core platform services. It covers practices such as combining or cross-using personal data without the required user choice and consent, restricting business users from steering customers to different prices or conditions, blocking access to content or subscriptions bought outside the gatekeeper channel, stopping complaints to public authorities, tying use of the gatekeeper's identification, browser-engine, or payment services, and daily advertising-price transparency for advertisers and publishers.

Article 6 contains obligations that can be further specified under Article 8. It covers product and technical conduct such as using non-public business-user data to compete with those users, uninstall and default-setting choice, installation and use of third-party apps and app stores, ranking self-preferencing, switching restrictions, operating-system or virtual-assistant interoperability, advertising measurement access, data portability, business-user data access, search data access, fair access conditions for app stores, search engines, and social networks, and termination conditions.

Article 7 is narrower: it applies where the gatekeeper provides designated number-independent interpersonal communications services. It requires interoperability for listed basic messaging, file-sharing, group, voice, and video-call functionalities through technical interfaces or similar solutions, while preserving security such as end-to-end encryption where applicable.

The useful evidence unit is an obligation-by-service record. For each Article 5, 6, or 7 requirement, the record should identify the designated core platform service, the product surface affected, the pre-change state, the implemented measure, the date of implementation, the geographic and product scope, and the supporting data or internal documents.

The Commission's Article 11 compliance-report template asks gatekeepers to explain compliance for each core platform service and each applicable obligation. It also points to evidence that product teams can actually maintain: engineering changes, API or operating-system functionality changes, ranking or advertising-auction parameters, consent forms, choice screens, warning messages, customer journeys, business-user terms, consultation input, testing, indicators, data access policies, retention policies, and security or privacy justifications.

That means a product ticket alone is not enough. The evidence should show both the control and its effect: for example, screenshots or demos for a choice screen, API documentation and access logs for interoperability, ranking-methodology records for self-preferencing controls, consent-rate and refusal handling records for data-combination controls, and advertiser or publisher data-export samples for advertising transparency.

Article 11 is the reporting bridge between the legal obligations and operational proof. Within 6 months after designation, the gatekeeper must give the Commission a detailed and transparent report describing the measures implemented to ensure compliance with Articles 5, 6, and 7, publish and provide a non-confidential summary, and update both at least annually.

The Article 11 template makes the report a living evidence register rather than a one-time narrative. Gatekeepers are expected to identify the people responsible for drafting the report, provide a compliance statement for each applicable obligation, explain the supporting data and internal documents, and highlight differences from prior reports when the report is updated.

For visitors assessing readiness, the practical implication is straightforward: if a measure cannot be described in the Article 11 format, it is probably not yet mature enough. A DMA control should have a named service, an obligation reference, a product implementation, data or screenshots that verify the implementation, and a non-confidential version that still gives third parties a meaningful picture.

Article 6(7) is the general hardware and software interoperability duty for operating systems and virtual assistants listed in a designation decision. The Commission's interoperability Q&A uses Apple iOS and iPadOS as a concrete example: it explains that Apple must provide developers and businesses with free and effective interoperability with hardware and software features controlled by those operating systems.

The same Q&A describes specification decisions for iOS interoperability with third-party connected devices and for the request process used by developers. Examples include access to iOS notifications, background execution, automatic audio switching, wireless file transfers, media casting, NFC reader/writer mode, proximity-triggered pairing, and automatic Wi-Fi connection. The Q&A also describes process evidence such as public guidance, request status tracking, rejection reasons, feedback, dispute steps, reporting metrics, and protection of non-public information received from developers.

Article 7 is separate from that Apple Article 6(7) example. It concerns designated number-independent interpersonal communications services and includes interoperability of basic functions such as end-to-end text messaging, file sharing, group messaging, and voice or video calls, with security and end-user choice preserved.