---
title: "What do DMA Articles 5, 6, and 7 require from gatekeepers?"
canonical_url: "https://www.sorena.io/artifacts/eu/digital-markets-act/faq/articles-5-6-and-7-obligations"
source_url: "https://www.sorena.io/artifacts/eu/digital-markets-act/faq/articles-5-6-and-7-obligations"
author: "Sorena AI"
description: "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."
published_at: "2026-05-09"
updated_at: "2026-05-09"
keywords:
  - "EU Digital Markets Act"
  - "DMA"
  - "Article 5"
  - "Article 6"
  - "Article 7"
  - "gatekeeper obligations"
  - "Article 11 compliance report"
---
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---

# 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.

*DMA FAQ* *Articles 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.

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

Under the EU Digital Markets Act, Articles 5, 6, and 7 do not apply as a loose company policy. A gatekeeper has to apply them to each core platform service listed in its designation decision, demonstrate effective compliance under Article 8, and report the implemented measures under Article 11. Timings in this page are source-linked; verify current legal source language before implementation decisions.

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

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.

- Do not summarize Articles 5, 6, and 7 as one generic compliance duty; map each obligation to the affected core platform service.
- 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 number-independent interpersonal communications services.

Sources for this answer:

- [Regulation (EU) 2022/1925 (Digital Markets Act)](https://eur-lex.europa.eu/eli/reg/2022/1925/oj?ref=sorena.io) - Primary DMA text for the obligations in Articles 5, 6, and 7 and their application to listed core platform services.
- [European Commission DMA legislation page](https://digital-markets-act.ec.europa.eu/legislation_en?ref=sorena.io) - Commission page linking the DMA legislation and implementing materials that frame how the rules are administered.

## 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 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.

- Link every measure to a specific Article paragraph, core platform service, 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 core platform service.

Sources for this answer:

- [Regulation (EU) 2022/1925 (Digital Markets Act)](https://eur-lex.europa.eu/eli/reg/2022/1925/oj?ref=sorena.io) - Article 8 requires gatekeepers to ensure and demonstrate effective compliance with Articles 5, 6, and 7.
- [European Commission Article 11 DMA compliance report template](https://digital-markets-act.ec.europa.eu/about-dma/practical-information_en?ref=sorena.io#templates) - Commission template specifying service-by-service and obligation-by-obligation evidence expected in Article 11 compliance reports.

## 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 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.

- 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.
- Update the report when measures, user journeys, APIs, service scope, rankings, ads data, terms, or evidence indicators materially change.
- Retain raw data and internal documents so they can be made available if the Commission asks for them.

Sources for this answer:

- [Regulation (EU) 2022/1925 (Digital Markets Act)](https://eur-lex.europa.eu/eli/reg/2022/1925/oj?ref=sorena.io) - Article 11 sets the compliance-report timing, non-confidential summary, and annual update obligation.
- [European Commission Article 11 DMA compliance report template](https://digital-markets-act.ec.europa.eu/about-dma/practical-information_en?ref=sorena.io#templates) - Template support for compliance statements, supporting data, internal documents, non-confidential summaries, and report updates.

## What Article 6 and Article 7 interoperability examples are grounded in DMA sources?

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.

- 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.

Sources for this answer:

- [Regulation (EU) 2022/1925 (Digital Markets Act)](https://eur-lex.europa.eu/eli/reg/2022/1925/oj?ref=sorena.io) - Primary text for Article 6(7) hardware and software interoperability and Article 7 messaging interoperability obligations.
- [European Commission DMA interoperability questions and answers](https://digital-markets-act.ec.europa.eu/questions-and-answers/interoperability_en?ref=sorena.io) - Commission Q&A giving concrete Apple iOS and iPadOS examples for Article 6(7) interoperability implementation and request handling.

## Primary sources

- [Regulation (EU) 2022/1925 (Digital Markets Act)](https://eur-lex.europa.eu/eli/reg/2022/1925/oj?ref=sorena.io) - Primary legal source for gatekeeper obligations in Articles 5, 6, and 7, Article 8 demonstration, Article 11 reporting, and Article 13 anti-circumvention.
  - Quote: "The gatekeeper shall ensure and demonstrate compliance"
- [European Commission DMA legislation page](https://digital-markets-act.ec.europa.eu/legislation_en?ref=sorena.io) - Commission landing page for the DMA legislation and related implementing materials.
  - Quote: "The DMA contains the main rules"
- [European Commission Article 11 DMA compliance report template](https://digital-markets-act.ec.europa.eu/about-dma/practical-information_en?ref=sorena.io#templates) - Official template for the evidence, compliance statements, supporting data, internal documents, and non-confidential summaries used in Article 11 reporting.
  - Quote: "Compliance Report Template Form"
- [European Commission DMA interoperability questions and answers](https://digital-markets-act.ec.europa.eu/questions-and-answers/interoperability_en?ref=sorena.io) - Commission Q&A with concrete Article 6(7) interoperability examples and request-process expectations for iOS and iPadOS.
  - Quote: "Interoperability Questions and Answers"

## Topic Guides

- [DMA Anti-Circumvention Design Review for Gatekeeper Product Changes](/artifacts/eu/digital-markets-act/anti-circumvention-design-review.md): Review DMA Article 13 anti-circumvention risks in gatekeeper product, interface, contractual, commercial, and technical changes with obligation mapping and evidence records.
- [DMA Article 11 Compliance Report Template FAQ](/artifacts/eu/digital-markets-act/faq/compliance-report-template.md): How gatekeepers should use the DMA Article 11 compliance report template to document obligation-by-obligation measures, evidence, updates, and non-confidential summaries.
- [DMA Article 6 Business User Data Access Guide](/artifacts/eu/digital-markets-act/business-user-data-access.md): Grounded 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](/artifacts/eu/digital-markets-act/article-6-7-interoperability.md): Grounded 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](/artifacts/eu/digital-markets-act/core-obligations-by-obligation.md): 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](/artifacts/eu/digital-markets-act/compliance-program-and-monitoring.md): 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](/artifacts/eu/digital-markets-act/core-platform-service-scoping-by-service.md): Scope EU Digital Markets Act core platform services by service category, designation evidence, user thresholds, and Form GD service-boundary records.
- [DMA core platform services FAQ](/artifacts/eu/digital-markets-act/faq/core-platform-services.md): 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 CPS Obligation Matrix Workflow: Articles 5, 6, 7 and Article 11 Evidence](/artifacts/eu/digital-markets-act/cps-obligation-matrix-workflow.md): 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 designation intake workflow for gatekeeper notifications](/artifacts/eu/digital-markets-act/designation-intake-workflow.md): Build a grounded DMA designation intake record covering core platform service classification, Article 3 thresholds, Form GD evidence, Commission handoff, and Article 11 readiness.
- [DMA enforcement, penalties, and remedies: Commission powers and evidence](/artifacts/eu/digital-markets-act/enforcement-penalties-and-remedies.md): EU Digital Markets Act enforcement guide covering Commission non-compliance decisions, DMA fine caps, periodic penalty payments, remedies, interim measures, commitments, and Article 11 evidence.
- [DMA Gatekeeper Compliance Checklist for Articles 5, 6, 7 and 11](/artifacts/eu/digital-markets-act/gatekeeper-compliance-checklist.md): A grounded 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](/artifacts/eu/digital-markets-act/gatekeeper-designation-guide.md): A grounded 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 gatekeeper thresholds: what counts and when to notify](/artifacts/eu/digital-markets-act/faq/gatekeeper-thresholds.md): 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](/artifacts/eu/digital-markets-act/faq/interoperability-requests.md): How EU Digital Markets Act interoperability requests work for Article 7 messaging services, Article 6(7) operating-system access, gatekeeper evidence, requester evidence, and security safeguards.
- [DMA penalties and fines: caps, triggers, and enforcement evidence](/artifacts/eu/digital-markets-act/penalties-and-fines.md): EU Digital Markets Act penalties guide covering Article 30 fine caps, Article 31 periodic penalty payments, non-compliance decisions, remedies, and evidence records.
- [DMA Product Change Review Workflow for Articles 5, 6, 7, 11 and 13](/artifacts/eu/digital-markets-act/product-change-review-workflow.md): 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](/artifacts/eu/digital-markets-act/self-preferencing-compliance-examples.md): 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](/artifacts/eu/digital-markets-act/dma-vs-data-act.md): 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](/artifacts/eu/digital-markets-act/dma-vs-dsa.md): A grounded comparison of the DMA and DSA focused on gatekeepers, core platform services, DMA obligations, Article 11 reporting, interoperability, data access, and enforcement.
- [DMA vs EU competition law: gatekeeper obligations, Article 11 evidence, and enforcement](/artifacts/eu/digital-markets-act/dma-vs-eu-competition-law.md): 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](/artifacts/eu/digital-markets-act/dma-vs-gdpr.md): Compare DMA gatekeeper obligations with high-level GDPR overlap for consent, combining personal data, data access, portability, and Article 11 reporting.
- [EU Digital Markets Act Article 11 Evidence Calendar](/artifacts/eu/digital-markets-act/annual-report-evidence-calendar.md): Build a source-grounded DMA Article 11 compliance report calendar with evidence owners, annual update checkpoints, report sections, and review gates.
- [EU Digital Markets Act checklist for gatekeeper compliance](/artifacts/eu/digital-markets-act/checklist.md): A source-grounded 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](/artifacts/eu/digital-markets-act/compliance.md): 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](/artifacts/eu/digital-markets-act/deadlines-and-compliance-calendar.md): Track DMA notification, designation, six-month obligation start, Article 11 reporting, Article 14 concentration notices, Article 15 profiling audits, and preparation milestones using official EU sources.
- [EU Digital Markets Act FAQ: gatekeepers, DMA obligations, reports, and enforcement](/artifacts/eu/digital-markets-act/faq.md): 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](/artifacts/eu/digital-markets-act/requirements.md): 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 and Key Milestones: practical obligations and evidence guide](/artifacts/eu/digital-markets-act/timeline-and-key-milestones.md): Practical EU Digital Markets Act guide to Timeline and Key Milestones: scope, owners, evidence, edge cases, checklist steps, and external source-linked citations.
- [EU DMA Applicability Test: gatekeeper thresholds, core platform services, and evidence](/artifacts/eu/digital-markets-act/applicability-test.md): 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](/artifacts/eu/digital-markets-act/article-11-reporting.md): Source-grounded 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](/artifacts/eu/digital-markets-act/dos-and-donts-for-product-teams.md): 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.

*Recommended next step*

*Placement: before sources*

## Build an Article 11-ready DMA evidence register

Use the cited sources listed here to verify obligations and the supporting evidence requirements.

- [Open Research Copilot for the Digital Markets Act](/solutions/research-copilot.md): Verify the following areas from the cited sources:  DMA gatekeeper obligations, Article 11 evidence, interoperability, and compliance-report structure.
- [Review DMA implementation evidence](/contact.md): Check whether your Article 5, 6, and 7 controls can be explained service by service in the Article 11 reporting format.


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