---
title: "DMA gatekeeper thresholds: what counts and when to notify"
canonical_url: "https://www.sorena.io/artifacts/eu/digital-markets-act/faq/gatekeeper-thresholds"
source_url: "https://www.sorena.io/artifacts/eu/digital-markets-act/faq/gatekeeper-thresholds"
author: "Sorena AI"
description: "Standalone FAQ on the EU Digital Markets Act gatekeeper thresholds, Article 3 notification timing, Form GD evidence, and active user-count methodology."
published_at: "2026-05-09"
updated_at: "2026-05-09"
keywords:
  - "EU Digital Markets Act"
  - "DMA gatekeeper thresholds"
  - "Article 3 DMA"
  - "Form GD"
  - "core platform service"
  - "active end users"
  - "active business users"
  - "DMA"
  - "gatekeeper thresholds"
  - "Article 3"
---
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---

# DMA gatekeeper thresholds: what counts and when to notify

Standalone FAQ on the EU Digital Markets Act gatekeeper thresholds, Article 3 notification timing, Form GD evidence, and active user-count methodology.

*FAQ* *EU DMA*

## DMA gatekeeper thresholds what counts and when to notify

A company is presumed to meet the DMA gatekeeper designation tests only when the Article 3 financial, user-reach, and durability thresholds line up for a core platform service.

Use this FAQ to separate the legal threshold test from market guesses: check the undertaking, each core platform service, Form GD evidence, and the Annex user-count methodology before treating a service as notifiable.

Under Article 3 of the EU Digital Markets Act, gatekeeper status is a designation by the European Commission, not a label that a business can self-apply from revenue alone. The threshold screen asks whether an undertaking has significant internal-market impact, provides a core platform service that is an important gateway between business users and end users, and has an entrenched and durable position or is expected to have one soon. Timings in this page are source-linked; verify current legal source language before implementation decisions.

## What are the DMA gatekeeper thresholds?

Article 3 creates three cumulative gatekeeper requirements and then sets quantitative presumptions for them. For significant internal-market impact, the undertaking is presumed to qualify if it has annual Union turnover of at least EUR 7.5 billion in each of the last three financial years, or average market capitalisation or equivalent fair market value of at least EUR 75 billion in the last financial year, and provides the same core platform service in at least three Member States.

For the gateway requirement, the relevant core platform service must have had, in the last financial year, at least 45 million monthly active end users established or located in the Union and at least 10,000 yearly active business users established in the Union. For the entrenched-and-durable-position presumption, those user thresholds must have been met in each of the last three financial years.

- Do not aggregate all products together unless the DMA core platform service delineation supports doing so.
- Check the undertaking-level financial threshold separately from the service-level EU user thresholds.
- Use the Annex methodology for active end users and active business users before deciding whether Article 3(2)(b) is met.
- Treat the threshold result as a notification and designation question; only the Commission designates a gatekeeper.

Sources for this answer:

- [Regulation (EU) 2022/1925 - Article 3 gatekeeper designation](https://eur-lex.europa.eu/eli/reg/2022/1925/2022-10-12/eng?ref=sorena.io) - Supports the three Article 3 designation requirements, the financial and user threshold presumptions, the two-month notification rule, and the Commission designation timing.
- [European Commission - DMA legislation](https://digital-markets-act.ec.europa.eu/legislation_en?ref=sorena.io) - Commission overview linking the DMA text, the procedural implementing regulation, Form GD, and designation-process materials.

## What happens after the thresholds are met?

If an undertaking providing core platform services meets all Article 3(2) thresholds, Article 3(3) requires notification to the Commission without delay and within two months after the thresholds are met. The notification must include the relevant threshold information for each core platform service that meets the user threshold.

After receiving complete information, the Commission must designate the undertaking as a gatekeeper without undue delay and at the latest within 45 working days if the thresholds are met. A previously designated gatekeeper must also notify when another core platform service later meets the relevant user and durability thresholds.

- Prepare one threshold file per relevant core platform service, including any plausible alternative service delineations.
- Track the two-month notification trigger from the point the Article 3(2) thresholds are met.
- Keep the completeness review visible because incomplete, incorrect, or misleading information can affect the effective date of the notification.
- Escalate when an already designated gatekeeper launches or grows another service that may newly meet Article 3(2)(b) and (c).

Sources for this answer:

- [Regulation (EU) 2022/1925 - Article 3 notification and designation](https://eur-lex.europa.eu/eli/reg/2022/1925/2022-10-12/eng?ref=sorena.io) - Article 3(3) and 3(4) ground the notification obligation, the two-month notification period, and the 45-working-day designation period after complete information.
- [Commission Implementing Regulation (EU) 2023/814](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32023R0814&ref=sorena.io) - Procedural regulation explaining notification content, completeness, substantiated arguments, business-secret handling, language, authorisation, and effective-date rules.

## What evidence belongs in Form GD?

Form GD is the notification form for Article 3(3) gatekeeper designation. It asks for information about the notifying undertaking, its corporate structure, the entities operating each core platform service, contact details, and whether the undertaking has already been designated for any core platform services.

For threshold evidence, Form GD requires an exhaustive list of core platform services and plausible alternative delineations, explanations of the boundaries between distinct services, Union turnover for each of the last three financial years, average market capitalisation or equivalent fair market value for the last financial year, Member States where each service is provided, monthly active end users in the Union, yearly active business users in the Union, methodology explanations, and external reports or internal documents relied on for the user figures.

- Map each product to a DMA core platform service category before calculating users.
- Document broader and narrower plausible service delineations where the boundary is contestable.
- Separate undertaking-level financial data from service-level user counts.
- Attach methodology notes and source documents for Sections 4.1 and 4.2 instead of relying on a spreadsheet total alone.
- If rebutting the presumption, prepare a separate annex for each distinct core platform service.

Sources for this answer:

- [Commission Implementing Regulation (EU) 2023/814 - Form GD](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32023R0814&ref=sorena.io) - Annex I Form GD grounds the undertaking, core-platform-service, financial, user-count, methodology, document-support, declaration, and rebuttal-annex evidence fields.
- [European Commission - DMA legislation](https://digital-markets-act.ec.europa.eu/legislation_en?ref=sorena.io) - Commission legislation page identifies Form GD as the notification form potential gatekeepers use when providing figures in the designation process.

## How should CPS user counts be calculated?

The DMA Annex uses unique users for each core platform service. Active end users are counted once for the relevant service over a month, and active business users are counted once over a year, even if they engage many times during that period. The same person or entity can still be an active user for different core platform services.

Monthly active end users are based on the average number of monthly active end users throughout the largest part of the financial year. Signed-in or logged-in data is treated as the lowest duplication-risk source where it exists; where services are also used outside signed-in environments, the undertaking must also submit aggregate anonymized data based on an alternate metric if those identifiers are objectively necessary for providing the service. Business users are counted at business-account level where that concept applies.

- Use aggregate anonymized signed-in or logged-in unique-user data where available.
- Explain how the count avoids under-counting and over-counting across devices and platforms.
- Identify estimates as estimates and document the best available approximation method.
- Keep annually recurring events separate from outliers; recurring promotions are not treated as outliers under the Annex explanation.
- Do not use the Annex as a reason to create new user tracking; the Annex says it is not a legal basis for tracking users.

Sources for this answer:

- [Regulation (EU) 2022/1925 - Annex user-count methodology](https://eur-lex.europa.eu/eli/reg/2022/1925/2022-10-12/eng?ref=sorena.io) - The Annex grounds the unique-user approach, monthly and yearly counting periods, signed-in and alternate metrics, outlier treatment, and responsibility for complete and accurate user-count submissions.
- [Commission Implementing Regulation (EU) 2023/814 - Form GD Section 4](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32023R0814&ref=sorena.io) - Form GD Section 4 requires service-by-service active end-user and active business-user figures for the last three financial years, methodology explanations, and supporting documents.

## Can a company rebut the gatekeeper presumption?

Yes, but the rebuttal is narrow and evidence-heavy. Article 3(5) allows the undertaking to present sufficiently substantiated arguments showing that, exceptionally, although it meets all Article 3(2) thresholds, the circumstances of the relevant core platform service mean it does not satisfy the Article 3(1) requirements.

The implementing regulation requires those arguments to be filed with the notification in an annex. There must be a separate annex for each distinct core platform service, and the undertaking must identify which Article 3(1) requirement the argument addresses and explain why the corresponding threshold presumption is not satisfied for that service.

- Do not treat a rebuttal memo as a reason to skip notification when all Article 3(2) thresholds are met.
- Tie each rebuttal argument to significant impact, gateway function, or entrenched and durable position.
- Keep rebuttal evidence service-specific rather than relying on group-level narratives.
- Remember that the Commission may reject insufficiently substantiated arguments that do not manifestly call the presumptions into question.

Sources for this answer:

- [Regulation (EU) 2022/1925 - Article 3(5)](https://eur-lex.europa.eu/eli/reg/2022/1925/2022-10-12/eng?ref=sorena.io) - Article 3(5) grounds the ability to present sufficiently substantiated arguments against the Article 3(2) presumptions and the Commission's ability to reject weak arguments.
- [Commission Implementing Regulation (EU) 2023/814 - substantiated arguments annex](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32023R0814&ref=sorena.io) - Article 2(3) and Annex II ground the separate-annex requirement and the 30-page limit for Article 3(5) substantiated arguments per distinct core platform service.

## Primary sources

- [Regulation (EU) 2022/1925 - Digital Markets Act](https://eur-lex.europa.eu/eli/reg/2022/1925/2022-10-12/eng?ref=sorena.io) - Primary legal source for Article 3 gatekeeper designation requirements, threshold presumptions, notification timing, rebuttal rules, and Annex active-user methodology.
  - Quote: "Designation of gatekeepers"
- [Commission Implementing Regulation (EU) 2023/814](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32023R0814&ref=sorena.io) - Primary procedural source for Form GD, notification content, completeness, confidentiality handling, effective-date rules, and substantiated-argument annexes.
  - Quote: "FORM RELATING TO THE NOTIFICATION"
- [European Commission - DMA legislation](https://digital-markets-act.ec.europa.eu/legislation_en?ref=sorena.io) - Commission overview page connecting the DMA, the procedural implementing regulation, Form GD, and DMA designation-process materials.
  - Quote: "main rules for the designation of gatekeepers"
- [European Commission - DMA gatekeepers](https://digital-markets-act.ec.europa.eu/gatekeepers_en?ref=sorena.io) - Commission page for checking published gatekeeper designation decisions and listed core platform services, without publishing live company-count claims on this FAQ.
  - Quote: "Gatekeepers"

## 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 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.
- [What do DMA Articles 5, 6, and 7 require from gatekeepers?](/artifacts/eu/digital-markets-act/faq/articles-5-6-and-7-obligations.md): 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.

*Recommended next step*

*Placement: before sources*

## Check the DMA threshold facts before treating a service as notifiable

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

- [Open Research Copilot for EU Digital Markets Act](/solutions/research-copilot.md): Verify the following areas from the cited sources:  Article 3 thresholds, Form GD fields, CPS user counts, rebuttal evidence, and Commission designation materials.
- [Talk through implementation](/contact.md): Review your DMA threshold screen, source gaps, and Form GD evidence map with Sorena.


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