DMA FAQArticles 5, 6, and 7

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

Articles 5, 6, and 7 are the main DMA obligation set for designated gatekeepers and the core platform services named in their designation decisions.

This FAQ helps separate the obligation groups, identify product and evidence owners, and connect service-level implementation work to the Article 11 compliance report.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

Under the EU Digital Markets Act, a designated must apply Articles 5, 6, and 7 to each listed in its designation decision. It must comply within six months after the relevant service is listed in the designation decision, demonstrate under Article 8, and report the implemented measures under Article 11. A specification request or proceeding does not by itself suspend the obligation.

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4 of 4 questions
Question 1

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

Article 5 contains direct 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 provides designated . It requires interoperability through technical interfaces or similar solutions, upon request and free of charge. One-to-one text messaging and attached-file sharing apply following listing, subject to the general six-month compliance period; group messaging applies within two years after designation; and listed voice and video call functions apply within four years. The gatekeeper must preserve the security level, including end-to-end encryption where applicable.

  • Do not summarize Articles 5, 6, and 7 as one generic compliance duty; map each obligation to the affected .
  • Treat Article 5 issues as direct conduct controls, especially data combination, anti-steering, tying, complaints, and advertising transparency.
  • Treat Article 6 issues as product, access, ranking, data, portability, switching, and interoperability controls that may require technical specification.
  • Treat Article 7 as the special interoperability regime for .
  • Check any Article 9 suspension or Article 10 exemption decision separately. Those are Commission decisions subject to statutory conditions, not internal non-applicability judgments.

What do EU Digital Markets Act Articles 5, 6, and 7 require from gatekeepers?

They require designated gatekeepers to change specific conduct for each listed within six months after that service is listed. Article 5 addresses direct bans and duties such as data-combination consent, anti-steering, tying, complaints, and advertising transparency. Article 6 addresses product, data, ranking, switching, access, portability, and interoperability obligations that the Commission can further specify. Article 7 establishes a phased interoperability regime for designated .

Can a delay compliance while asking for specification, suspension, or exemption?

A cannot delay compliance merely because it asks the Commission to specify measures under Article 8(3). Suspension under Article 9 requires a Commission decision based on exceptional circumstances beyond the gatekeeper's control that would endanger the economic viability of its Union operation. Exemption under Article 10 also requires a Commission decision and is limited to public-health or public-security grounds. Until such relief applies, the gatekeeper must ensure and demonstrate .

Question 2

How should product and compliance teams prove these DMA obligations are implemented?

The useful evidence unit is an obligation-by-service record. For each Article 5, 6, or 7 requirement, the record should identify the designated , 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 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.

Evidence should show the control and its effect. Depending on the obligation, that may include 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, or advertiser and publisher data-export samples for advertising transparency. A product ticket alone does not provide that proof.

  • Link every measure to a specific Article paragraph, , owner, implementation artifact, and review trigger.
  • Keep before-and-after evidence where the obligation changes a user journey, business-user term, API, ranking method, payment flow, or data-use policy.
  • Document why any integrity, security, or privacy limit is strictly necessary and proportionate when the DMA text allows such limits.
  • Keep non-applicability explanations separate from implementation evidence; the template allows omission only where the obligation cannot by nature apply to that .
Question 3

How does Article 11 reporting connect to Articles 5, 6, and 7?

Article 11 is the reporting bridge between the legal obligations and operational proof. Within 6 months after designation, the 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 requires evidence that can be maintained across updates. 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.

Use the Article 11 structure as an internal completeness check. A DMA control record should name the service and obligation, describe the product implementation, identify data or documents supporting the explanation, and state how the measure will be described in the non-confidential summary.

  • Use Article 11 report sections as the filing structure for Article 5, 6, and 7 implementation evidence.
  • Prepare non-confidential summaries early so business secrets are protected without removing the substance needed for third-party input.
  • Review the report when measures, user journeys, APIs, service scope, rankings, advertising data, terms, or evidence indicators materially change; Article 11 requires an update at least annually.
  • Retain raw data and internal documents so they can be made available if the Commission asks for them.
Question 4

What Article 6 and Article 7 interoperability examples are based on DMA sources?

Article 6(7) is the hardware and software interoperability duty for operating systems and virtual assistants listed in a designation decision. The Commission's March 2025 Apple specification decisions provide a concrete example for iOS and iPadOS. They concern interoperability with connected devices and Apple's process for developer interoperability requests. Their binding measures apply to Apple in those proceedings; they do not automatically apply to every .

The Apple measures cover specified connectivity features and process controls, including public request guidance, request tracking, reasoned rejection notices, feedback and review routes, reporting metrics, and limits on access to non-public information received from developers. Use those details only when the Apple decisions are the relevant authority; use the DMA text and any service-specific Commission decision for other gatekeepers.

Article 7 is separate from that Apple Article 6(7) example. It concerns designated 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.

  • For Article 6(7), keep request intake, technical assessment, API or framework documentation, security justification, feedback, status tracking, and implementation-report evidence.
  • For Article 7, keep the reference offer, technical-interface records, request handling records, security and encryption analysis, personal-data minimisation analysis, and end-user choice evidence.
  • Do not merge Article 6(7) operating-system interoperability with Article 7 messaging-service interoperability; they have different service triggers and evidence needs.
  • Do not treat a security objection as self-proving; the DMA sources require strict necessity, proportionality, and justification where security or integrity limits are used.
Primary sources

References and citations

eur-lex.europa.eu5 citations
Referenced sections
  • Primary legal source for gatekeeper obligations in Articles 5, 6, and 7, Article 8 demonstration, Article 11 reporting, and Article 13 anti-circumvention.
  • Primary DMA text for the obligations in Articles 5, 6, and 7 and their application to listed core platform services.
  • Article 8 requires gatekeepers to ensure and demonstrate effective compliance with Articles 5, 6, and 7.
Show 2 more
  • Article 11 sets the compliance-report timing, non-confidential summary, and annual update obligation.
  • Primary text for Article 6(7) hardware and software interoperability and Article 7 messaging interoperability obligations.
"The gatekeeper shall ensure and demonstrate compliance"
More quoted passages
"The gatekeeper shall comply with all obligations set out in this Article"
"ensure and demonstrate compliance"
"update that report and that non-confidential summary at least annually"
"free of charge, effective interoperability"
digital-markets-act.ec.europa.eu3 citations
Referenced sections
  • Official template for the evidence, compliance statements, supporting data, internal documents, and non-confidential summaries used in Article 11 reporting.
  • Commission template specifying service-by-service and obligation-by-obligation evidence expected in Article 11 compliance reports.
  • Template support for compliance statements, supporting data, internal documents, non-confidential summaries, and report updates.
"Compliance Report Template Form"
More quoted passages
"for each core platform service"
digital-markets-act.ec.europa.eu2 citations
Referenced sections
  • Current Commission portal for Article 6(7) specification proceedings and gatekeeper-specific interoperability resources.
"Interoperability specification proceedings"
More quoted passages
"same OS hardware and software features"
digital-markets-act.ec.europa.eu2 citations
Referenced sections
  • Commission landing page for the DMA legislation and related implementing materials.
  • Commission page linking the DMA legislation and implementing materials that frame how the rules are administered.
"The DMA contains the main rules"
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