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19of19items
Across 5 modules • Updated Jul 26, 2026
Author
Sorena AI
Published
May 9, 2026
Updated
Jul 26, 2026
What do DMA Articles 5, 6, and 7 require from gatekeepers?

What do DMA Articles 5, 6, and 7 require from gatekeepers?

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 through technical interfaces or similar solutions, upon request and free of charge. One-to-one text messaging and attached-file sharing apply following listing, subject to the general six-month compliance period; group messaging applies within two years after designation; and listed voice and video call functions apply within four years. The gatekeeper must preserve the security level, including end-to-end encryption where applicable.

  • Do not summarize Articles 5, 6, and 7 as one generic compliance duty; map each obligation to the affected core platform service.
  • Treat Article 5 issues as direct conduct controls, especially data combination, anti-steering, tying, complaints, and advertising transparency.
  • Treat Article 6 issues as product, access, ranking, data, portability, switching, and interoperability controls that may require technical specification.
  • Treat Article 7 as the special interoperability regime for number-independent interpersonal communications services.
  • Check any Article 9 suspension or Article 10 exemption decision separately. Those are Commission decisions subject to statutory conditions, not internal non-applicability judgments.

What do EU Digital Markets Act Articles 5, 6, and 7 require from gatekeepers?

They require designated gatekeepers to change specific conduct for each listed core platform service within six months after designation. Article 5 addresses direct bans and duties such as data-combination consent, anti-steering, tying, complaints, and advertising transparency. Article 6 addresses product, data, ranking, switching, access, portability, and interoperability obligations that the Commission can further specify. Article 7 establishes a phased interoperability regime for designated number-independent interpersonal communications services.

Can a gatekeeper delay compliance while asking for specification, suspension, or exemption?

A gatekeeper cannot delay compliance merely because it asks the Commission to specify measures under Article 8(3). Suspension under Article 9 requires a Commission decision based on exceptional circumstances beyond the gatekeeper's control that would endanger the economic viability of its Union operation. Exemption under Article 10 also requires a Commission decision and is limited to public-health or public-security grounds. Until such relief applies, the gatekeeper must ensure and demonstrate effective compliance.

Citations
What do DMA Articles 5, 6, and 7 require from gatekeepers?

How should product and compliance teams prove these DMA obligations are implemented?

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.

Evidence should show the control and its effect. Depending on the obligation, that may include 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, or advertiser and publisher data-export samples for advertising transparency. A product ticket alone does not provide that proof.

  • Link every measure to a specific Article paragraph, core platform service, owner, implementation artifact, and review trigger.
  • Keep before-and-after evidence where the obligation changes a user journey, business-user term, API, ranking method, payment flow, or data-use policy.
  • Document why any integrity, security, or privacy limit is strictly necessary and proportionate when the DMA text allows such limits.
  • Keep non-applicability explanations separate from implementation evidence; the template allows omission only where the obligation cannot by nature apply to that core platform service.
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What do DMA Articles 5, 6, and 7 require from gatekeepers?

How does Article 11 reporting connect to Articles 5, 6, and 7?

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 requires evidence that can be maintained across updates. 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.

Use the Article 11 structure as an internal completeness check. A DMA control record should name the service and obligation, describe the product implementation, identify data or documents supporting the explanation, and state how the measure will be described in the non-confidential summary.

  • Use Article 11 report sections as the filing structure for Article 5, 6, and 7 implementation evidence.
  • Prepare non-confidential summaries early so business secrets are protected without removing the substance needed for third-party input.
  • Review the report when measures, user journeys, APIs, service scope, rankings, advertising data, terms, or evidence indicators materially change; Article 11 requires an update at least annually.
  • Retain raw data and internal documents so they can be made available if the Commission asks for them.
Citations
What do DMA Articles 5, 6, and 7 require from gatekeepers?

What Article 6 and Article 7 interoperability examples are based on DMA sources?

Article 6(7) is the hardware and software interoperability duty for operating systems and virtual assistants listed in a designation decision. The Commission's March 2025 Apple specification decisions provide a concrete example for iOS and iPadOS. They concern interoperability with connected devices and Apple's process for developer interoperability requests. Their binding measures apply to Apple in those proceedings; they do not automatically apply to every gatekeeper.

The Apple measures cover specified connectivity features and process controls, including public request guidance, request tracking, reasoned rejection notices, feedback and review routes, reporting metrics, and limits on access to non-public information received from developers. Use those details only when the Apple decisions are the relevant authority; use the DMA text and any service-specific Commission decision for other gatekeepers.

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.

  • For Article 6(7), keep request intake, technical assessment, API or framework documentation, security justification, feedback, status tracking, and implementation-report evidence.
  • For Article 7, keep the reference offer, technical-interface records, request handling records, security and encryption analysis, personal-data minimisation analysis, and end-user choice evidence.
  • Do not merge Article 6(7) operating-system interoperability with Article 7 messaging-service interoperability; they have different service triggers and evidence needs.
  • Do not treat a security objection as self-proving; the DMA sources require strict necessity, proportionality, and justification where security or integrity limits are used.
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