DMA Interoperability Requests Article 7 and Commission Guidance

First confirm that the request is really an Article 7 request: the gatekeeper must provide a number-independent interpersonal communication service listed in its DMA designation decision, and the requester must be another provider offering or intending to offer such services in the Union.

If that scope test is met, Article 7 requires the gatekeeper to provide the technical interfaces or similar solutions needed for interoperability, upon request and free of charge. The request can cover some or all of the basic functionalities listed in Article 7, and the gatekeeper must render reasonable requested functionalities operational within three months after receiving the request unless the Commission extends time limits on a reasoned gatekeeper request.

The request file should prove the Article 7 scope, the requested functionality, and the security and privacy handling. A requester should be able to show that it is offering or intends to offer a number-independent interpersonal communication service in the Union and that the request maps to Article 7 functionality. A gatekeeper should be able to show how it assessed the request against its reference offer and why any condition, limitation, sequencing decision, or refusal is grounded in the DMA standard.

Gatekeeper compliance evidence should also align with the Commission's Article 11 compliance-report template: for obligations under Articles 5 to 7, gatekeepers are expected to explain measures, scope, technical or engineering changes, security aspects, alternatives considered, and actions taken to protect integrity, security, or privacy.

The Commission's Apple interoperability Q&A is important, but it is mainly about Article 6(7) operating-system interoperability for iOS and iPadOS, not Article 7 messaging interoperability. It is still useful because it shows the kind of request-process discipline the Commission expects in a specified interoperability setting: transparent submission guidance, assessment criteria, feedback on proposed solutions, recourse for rejections, tracker visibility, protection of non-public requester information, and public reporting.

Do not copy Apple-specific implementation details into other gatekeepers or services unless the same obligation and source support apply. Use the Q&A as grounded Commission context for Article 6(7) iOS/iPadOS requests and as a caution that interoperability request processes should be explainable, documented, and reviewable.