DMA Interoperability Requests Article 7 and Commission Guidance

First confirm that the gatekeeper provides a number-independent interpersonal communications service listed in its DMA designation decision and that the requester offers or intends to offer such a service in the Union. A commercial integration request outside that scope is not an Article 7 request.

Article 7 requires the gatekeeper to provide the technical interfaces or similar solutions needed for interoperability, upon request and free of charge. A request may cover some or all functions that the gatekeeper itself provides and that have reached their statutory phase: one-to-one text and attached-file sharing following listing, subject to the general six-month compliance period; group messaging and group file sharing within two years after designation; and listed one-to-one or group voice and video calls within four years.

After the reference offer is published, the gatekeeper must render a reasonable request operational within three months after receipt. On a reasoned gatekeeper request, the Commission may exceptionally extend the phase-in or three-month deadline where needed for effective interoperability and the required security level.

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 offers or intends to offer a number-independent interpersonal communications service in the Union and that the request maps to a function in the applicable Article 7 phase. A gatekeeper should show how it assessed the request against its reference offer and why any condition, limitation, sequencing decision, or refusal follows 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.

No. A Commission specification decision under Article 6(7) binds the named gatekeeper and the operating-system or virtual-assistant features covered by that decision. It does not replace Article 7's requester test, phased functions, reference offer, three-month rule, or safeguards for messaging interoperability.

The Commission's March 2025 Apple decisions illustrate this boundary. They specify iOS and iPadOS connected-device features and Apple's developer request process, including submission guidance, assessment stages, feedback, review routes, tracking, information separation, and reporting. Those details apply to Apple under the decisions. For another gatekeeper or an Article 7 request, use the DMA text and the relevant designation or specification decision.