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 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.

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.

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.

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 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.

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 gatekeeper.

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 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.