FAQEU DMA

DMA Article 11 Compliance Report Template

The Article 11 template is the Commission's structure for a gatekeeper report that describes, core-platform-service by core-platform-service, how Articles 5 to 7 DMA obligations are implemented.

Use it to keep legal analysis, product implementation evidence, testing data, compliance-function records, and the public non-confidential summary aligned.

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Author

Sorena AI

Published

May 9, 2026

Updated

Jul 26, 2026

Questions

Structured answer sets in this page tree.

Primary sources

Cited legal and guidance references.

Publication metadata

Sorena AI

Published May 9, 2026

Updated Jul 26, 2026

Overview

A designated gatekeeper must give the Commission an within six months after designation, publish and provide a by the same deadline, and update both at least annually. The Commission's template, last updated on 9 October 2023, structures the report by designated core platform service and applicable Articles 5 to 7 obligation. Check the Commission's current practical-information page before filing because the Commission may update the template.

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3 of 3 questions

Question 1

What is the DMA Article 11 compliance report template for?

The template structures the Article 11 report as an evidence file. For each designated core platform service and each applicable Articles 5 to 7 obligation, the gatekeeper is expected to confirm compliance as of a stated date and explain exhaustively how it complies. A request for specification under Article 8(3), or related specification discussions, does not remove the duty to report on that obligation.

For each measure, identify the obligation, service, pre-designation or post-designation measure, implementation date, product and geographic scope, technical or engineering changes, customer-experience changes, effects on fees or terms, user consultation, testing, indicators, monitoring systems, and any data-access procedure that third parties use.

Create separate standalone annexes for each designated core platform service.
For each applicable Articles 5 to 7 obligation, keep a compliance statement, a plain-English measure description, supporting data, and internal documents.
Explain why an obligation cannot apply to a core platform service only when that conclusion follows from the obligation's nature, and keep the reasoning separate from Article 9 suspension or Article 10 exemption issues.
Keep underlying raw data ready for Commission requests and define metrics clearly enough that a reviewer can reproduce calculations.
The template says the report materials should be searchable and machine-readable. It also says the submission and each annex should end with a declaration signed by the head of the .

What is the DMA template for?

It is the Commission's template for the gatekeeper report required by DMA Article 11. The report describes, in a detailed and transparent way, the measures implemented to comply with Articles 5 to 7 for each designated core platform service, and it is paired with a for publication.

Citations

Regulation (EU) 2022/1925 (Digital Markets Act)

Article 11 requires a report on measures implemented for Articles 5, 6, and 7 and requires a non-confidential summary.

European Commission - Article 11 DMA Compliance Report Template Form

Official Commission template dated 9 October 2023, used for report structure, service annexes, compliance statements, evidence fields, testing, indicators, and the declaration.

Question 2

When should the report be filed and updated?

Article 11 sets the cadence: the first report is due within six months after designation under Article 3, and the report and must be updated at least annually.

The Commission template also expects change tracking. If a gatekeeper previously submitted a compliance report, the latest report and should highlight differences from the previous versions, including relevant annexes.

Maintain the six-month Article 11 reporting clock for every newly designated gatekeeper and the separate Article 3(10) compliance clock for every newly listed core platform service.
Schedule an annual refresh of the full report, annexes, and .
As an internal control, review the evidence when a compliance measure, interface, API, ranking parameter, data flow, consent design, term, fee structure, or Commission dialogue changes; the statutory update floor remains at least annual.
Keep clean and redline versions so reviewers can see what changed between submissions.

Does asking the Commission for specification pause the Article 11 report?

No. The Commission template states that an Article 8(3) specification request or specification discussions do not free the gatekeeper from submitting a compliance report covering the obligations involved in that request or process.

Citations

Regulation (EU) 2022/1925 (Digital Markets Act)

Article 11 provides the six-month initial reporting deadline and the annual update requirement.

European Commission - Article 11 DMA Compliance Report Template Form

The template explains redline-style change tracking and says specification discussions do not remove the reporting obligation.

Question 3

What should be public, confidential, and kept as records?

The full compliance report, annexes, and underlying data support the Commission's assessment. Article 11 separately requires a , and the Commission template says that summary should be self-standing, follow the same structure, cover all sections and sub-sections, and enable third parties to provide meaningful input.

Confidential treatment should be handled deliberately. The template says information may be omitted from the only if it is a business secret or otherwise confidential, and it asks gatekeepers to use meaningful ranges, baselines, or aggregated data for confidential numerical data rather than redacting entirely.

Keep a public-summary version that mirrors the full report structure and gives a faithful picture of every section.
Keep a confidential register that explains each redaction, the protected interest, and the replacement range, baseline, or aggregation used in the public summary.
Retain evidence for the : head-of-compliance involvement, monitoring role, management-body reports, risk-of-non-compliance reports, management replies, and approved compliance policies.
Keep feedback records from EU business users and end users, grouped by topic when there are more than ten instances, with actions taken and any anonymity or confidentiality request respected in the non-confidential description.

What practical records should sit behind each DMA Article 11 template answer?

Each answer should have an owner, service, obligation, implementation date, measure description, technical and customer-experience evidence, supporting data and methodology, testing or survey outputs, monitoring-system outputs, business-user or end-user feedback, compliance-function review, and a public-summary treatment that shows what was omitted or aggregated for confidentiality.

Citations

European Commission - Article 11 DMA Compliance Report Template Form

The template supports the non-confidential-summary structure, confidentiality approach, compliance-function records, feedback records, and declaration fields.

European Commission - Resources for gatekeepers and potential gatekeepers

Commission Q&A explains how confidential information and business secrets are identified and handled in DMA enforcement access-to-file processes.

European Commission - DMA gatekeepers page

Commission gatekeeper page links designated gatekeepers, core platform services, and published compliance-report materials.

Recommended next step

Build a report record that survives annual updates

Sorena can map each DMA obligation and core platform service to owners, implementation evidence, review triggers, confidentiality treatment, and the non-confidential summary.

Research workflow

Open Research Copilot for DMA reports

Verify Article 11 report fields, evidence records, update cadence, and public summaries from the cited sources.

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Talk to Sorena

Talk through implementation

Review your Article 11 report structure, evidence gaps, and non-confidential summary workflow with Sorena.

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Primary sources

References and citations

European Commission - Article 11 DMA Compliance Report Template Form

digital-markets-act.ec.europa.eu

Referenced sections

The template supports the non-confidential-summary structure, confidentiality approach, compliance-function records, feedback records, and declaration fields.