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.

Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Questions
3

Structured answer sets in this page tree.

Primary sources
5

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

A DMA Article 11 compliance report is not a general policy memo. A designated gatekeeper uses it to show the Commission, within six months after designation and at least annually after that, what measures it implemented for each applicable Articles 5 to 7 obligation and each designated core platform service. Timings in this page are source-linked; verify current legal source language before implementation decisions.

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3 of 3 questions
Question 1

What is the DMA Article 11 compliance report template for?

The template turns Article 11's reporting duty into a structured 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 the measure works.

A useful answer does not stop at saying that a control exists. It identifies the obligation, the service, the pre-designation or post-designation measure, the 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.
Citations
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 non-confidential summary 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 non-confidential summary should highlight differences from the previous versions, including relevant annexes.

  • Maintain a six-month designation clock for every newly designated gatekeeper or core platform service.
  • Schedule an annual refresh of the full report, annexes, and non-confidential summary.
  • Trigger an interim review when a compliance measure, interface, API, ranking parameter, data flow, consent design, terms, fee structure, or Commission dialogue changes.
  • Keep clean and redline versions so reviewers can see what changed between submissions.
Citations
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 non-confidential summary, 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 non-confidential summary 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 compliance function: 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.
Citations
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.

Primary sources

References and citations

digital-markets-act.ec.europa.eu
Referenced sections
  • Commission gatekeeper page links designated gatekeepers, core platform services, and published compliance-report materials.
"Compliance reports"
digital-markets-act.ec.europa.eu
Referenced sections
  • Commission Q&A explains how confidential information and business secrets are identified and handled in DMA enforcement access-to-file processes.
"identify any information containing business secrets"
eur-lex.europa.eu
Referenced sections
  • Article 11 provides the six-month initial reporting deadline and the annual update requirement.
"update that report and that non-confidential summary at least annually"
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