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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.

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.

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.

Article 2 of the DMA lists the core platform service categories: online intermediation services, online search engines, online social networking services, video-sharing platform services, number-independent interpersonal communications services, operating systems, web browsers, virtual assistants, cloud computing services, and online advertising services provided by an undertaking that also provides one of the other listed categories.

A service-scope answer should name the category, explain the product boundary, and identify whether the Commission has listed that service in a gatekeeper designation decision. The label used in a product roadmap is not enough; the DMA analysis turns on the Article 2 category and the service that is an important gateway for business users to reach end users.

Article 3 designates an undertaking as a gatekeeper when it has significant impact on the internal market, provides a core platform service that is an important gateway for business users to reach end users, and has an entrenched and durable position or is expected to have one soon. The quantitative presumption uses business-size evidence plus service-level user evidence.

For the user-gateway presumption, the DMA threshold is 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 core platform service in the last financial year. The Annex requires unique users to be counted once for the relevant service and period: monthly for active end users and yearly for active business users.

The DMA Annex is the most useful scoping control because it explains how active end users and active business users are identified for each category. It also gives boundary rules: services in the same category should not be split mainly by domain name or geography, while services used for different purposes can be treated as distinct even when users overlap.

A good scoping file therefore separates category, user purpose, business-user route to end users, metrics, and designation status. It should also name category-specific counting logic: for example, search uses queries and indexed business websites, operating systems use activated or used devices and developers, and online advertising uses advertisement-impression and advertiser or intermediary interactions.

Article 11 reporting is organised by designated core platform service and applicable obligation. The Commission template says each designated gatekeeper must provide a compliance report within 6 months after designation, update it at least annually, and provide separate standalone annexes for each core platform service for which it has been designated.

For each core platform service and each applicable Articles 5 to 7 obligation, the template asks for a compliance statement, an exhaustive explanation of measures, supporting data and internal documents, implementation timing, product and geographic scope, technical and engineering changes, customer-experience changes, remuneration and terms changes, consultation with users or interested parties, testing and indicators, monitoring systems, and feedback from business users or end users.

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.

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.

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.

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.

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.

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.

Article 5 contains direct gatekeeper obligations for the listed core platform services. It covers practices such as combining or cross-using personal data without the required user choice and consent, restricting business users from steering customers to different prices or conditions, blocking access to content or subscriptions bought outside the gatekeeper channel, stopping complaints to public authorities, tying use of the gatekeeper's identification, browser-engine, or payment services, and daily advertising-price transparency for advertisers and publishers.

Article 6 contains obligations that can be further specified under Article 8. It covers product and technical conduct such as using non-public business-user data to compete with those users, uninstall and default-setting choice, installation and use of third-party apps and app stores, ranking self-preferencing, switching restrictions, operating-system or virtual-assistant interoperability, advertising measurement access, data portability, business-user data access, search data access, fair access conditions for app stores, search engines, and social networks, and termination conditions.

Article 7 is narrower: it applies where the gatekeeper provides designated number-independent interpersonal communications services. It requires interoperability for listed basic messaging, file-sharing, group, voice, and video-call functionalities through technical interfaces or similar solutions, while preserving security such as end-to-end encryption where applicable.

The useful evidence unit is an obligation-by-service record. For each Article 5, 6, or 7 requirement, the record should identify the designated core platform service, the product surface affected, the pre-change state, the implemented measure, the date of implementation, the geographic and product scope, and the supporting data or internal documents.

The Commission's Article 11 compliance-report template asks gatekeepers to explain compliance for each core platform service and each applicable obligation. It also points to evidence that product teams can actually maintain: engineering changes, API or operating-system functionality changes, ranking or advertising-auction parameters, consent forms, choice screens, warning messages, customer journeys, business-user terms, consultation input, testing, indicators, data access policies, retention policies, and security or privacy justifications.

That means a product ticket alone is not enough. The evidence should show both the control and its effect: for example, screenshots or demos for a choice screen, API documentation and access logs for interoperability, ranking-methodology records for self-preferencing controls, consent-rate and refusal handling records for data-combination controls, and advertiser or publisher data-export samples for advertising transparency.

Article 11 is the reporting bridge between the legal obligations and operational proof. Within 6 months after designation, the gatekeeper must give the Commission a detailed and transparent report describing the measures implemented to ensure compliance with Articles 5, 6, and 7, publish and provide a non-confidential summary, and update both at least annually.

The Article 11 template makes the report a living evidence register rather than a one-time narrative. Gatekeepers are expected to identify the people responsible for drafting the report, provide a compliance statement for each applicable obligation, explain the supporting data and internal documents, and highlight differences from prior reports when the report is updated.

For visitors assessing readiness, the practical implication is straightforward: if a measure cannot be described in the Article 11 format, it is probably not yet mature enough. A DMA control should have a named service, an obligation reference, a product implementation, data or screenshots that verify the implementation, and a non-confidential version that still gives third parties a meaningful picture.

Article 6(7) is the general hardware and software interoperability duty for operating systems and virtual assistants listed in a designation decision. The Commission's interoperability Q&A uses Apple iOS and iPadOS as a concrete example: it explains that Apple must provide developers and businesses with free and effective interoperability with hardware and software features controlled by those operating systems.

The same Q&A describes specification decisions for iOS interoperability with third-party connected devices and for the request process used by developers. Examples include access to iOS notifications, background execution, automatic audio switching, wireless file transfers, media casting, NFC reader/writer mode, proximity-triggered pairing, and automatic Wi-Fi connection. The Q&A also describes process evidence such as public guidance, request status tracking, rejection reasons, feedback, dispute steps, reporting metrics, and protection of non-public information received from developers.

Article 7 is separate from that Apple Article 6(7) example. It concerns designated number-independent interpersonal communications services and includes interoperability of basic functions such as end-to-end text messaging, file sharing, group messaging, and voice or video calls, with security and end-user choice preserved.