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The template structures the Article 11 report as an 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 it complies. A request for specification under Article 8(3), or related specification discussions, does not remove the duty to report on that obligation.

For each measure, identify the obligation, service, pre-designation or post-designation measure, 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(2) lists ten 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 another listed core platform service. Software application stores are included within online intermediation services; they are not an eleventh category.

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 same user thresholds must have been met in each of the last three financial years for the entrenched-and-durable-position presumption. 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 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.