DMA gatekeeper compliance checklist

Start with the Commission designation decision, not with a product roadmap label. Article 3 requires the designation decision to list the relevant core platform services, and Article 5, Article 6 and Article 7 apply with respect to each listed service.

A checklist row should be opened only when it names the designated undertaking, the listed core platform service, the obligation article and paragraph, the affected business-user or end-user group, and the system or policy owner that can change the service.

Article 5 obligations are directly framed as conduct rules. The checklist should translate each relevant paragraph into an enforceable product, commercial, advertising, payments, account, or complaint-handling control.

Do not close an Article 5 row with a policy statement alone. The row should show the user journey, contract term, system rule, monitoring metric, and exception path that make the obligation effective.

Article 6 contains obligations that often need engineering, data, ranking, default-setting, interoperability, portability, and access-control evidence. Article 7 adds a specific interoperability regime for number-independent interpersonal communications services where that service is listed in the designation decision.

For each technical access obligation, the owner field should name both the policy approver and the system team that can prove the API, interface, data export, ranking change, or default-setting change works in production.

Article 11 requires a detailed and transparent report describing the measures implemented to ensure compliance with Articles 5, 6 and 7, plus a non-confidential summary. The Commission template makes the evidence standard concrete: each obligation and each core platform service needs a standalone explanation with supporting data and internal documents.

The evidence pack should be usable by the compliance function, management body, external counsel or technical experts, and Commission reviewers without relying on undocumented project history.

A DMA checklist row should not close merely because a control exists. Article 8 requires the gatekeeper to ensure and demonstrate effective compliance, and Article 13 prohibits contractual, commercial, technical, interface-design, or other behaviour that undermines effective compliance.

Use these gates whenever a feature ships, a policy changes, an API is launched or restricted, a business-user complaint identifies friction, or a Commission request or specification process affects the row.