Artifact GuideEU DMA

DMA self-preferencing compliance examples

Use this page to review product changes that can favour a gatekeeper's own services or products in ranking, indexing, crawling, search results, marketplace display, app-store placement, social feeds, video surfaces, or virtual-assistant answers.

The examples are grounded in DMA Article 6(5), Article 2 definitions of ranking and search results, recital examples of preferential treatment, and the Article 11 compliance-report template.

Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Sections
5

Structured answer sets in this page tree.

Primary sources
6

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

DMA Article 6(5) is not a general ban on showing a gatekeeper's own product. It is a rule for designated gatekeepers: in ranking and related indexing and crawling, the gatekeeper must not treat its own services or products more favourably than similar third-party services or products, and the ranking conditions must be transparent, fair, and non-discriminatory. A useful compliance review therefore starts with the product surface, identifies the comparable third-party offering, and tests whether legal, commercial, technical, or interface choices give the gatekeeper's own offering a better position or equivalent advantage. Timings in this page are source-linked; verify current legal source language before implementation decisions.

Section 1

What Article 6(5) covers

Scope the review to a designated gatekeeper, a core platform service listed in the designation decision, and a surface where goods, services, apps, videos, marketplace offers, social posts, search results, or assistant responses receive relative prominence.

The DMA definition of ranking is broad. It covers relative prominence in online intermediation services, online social networking services, video-sharing platform services, virtual assistants, and relevance in online search results, regardless of the technical presentation method and even where only one result is communicated.

  • In scope: ranking, related indexing, related crawling, display prominence, ratings, linking, voice results, and other measures with equivalent effect when they favour the gatekeeper's own service or product.
  • In scope: search results, including paid or unpaid results, direct answers, embedded products or services, and information displayed alongside organic results.
  • In scope: products or services offered by the gatekeeper itself or through a business user it controls, compared with similar third-party products or services on the same covered surface.
  • Out of scope for this page: general app uninstall, switching, interoperability, advertising transparency, and data-access obligations unless the same release also changes ranking, indexing, crawling, or display prominence.
Section 2

Grounded compliance examples

Use these examples as review patterns, not as a substitute for checking the exact designated core platform service and release facts. Each example should be tested against whether the gatekeeper's own product receives a better position or equivalent advantage than a similar third-party product.

A compliant implementation should be able to explain the ranking condition, apply it consistently to similar own and third-party offerings, and preserve product evidence showing that the rule was followed before and after release.

  • Online search: a direct answer, specialised result group, embedded widget, or vertical box should not reserve better placement for the gatekeeper's own service when similar third-party services compete for that same result surface.
  • Marketplace search or browsing: ranking, badges, filters, default sorting, sponsored/organic separation, and product-card display should not give the gatekeeper's own retail offer or controlled seller a more favourable position than similar third-party offers through legal, commercial, or technical means.
  • App store distribution: search results, editorial collections, category rankings, recommendation modules, ratings display, and install prompts should use transparent, fair, and non-discriminatory conditions where the gatekeeper's own app competes with similar third-party apps.
  • Video-sharing or social feeds: feed prominence, recommendation slots, preview formats, labels, and linking should not give the gatekeeper's own videos, services, or controlled business users preferential treatment over similar third-party offerings.
  • Virtual assistant or voice result: a single spoken answer, default service suggestion, link, or handoff can still be ranking under the DMA, so the release review should test whether the gatekeeper's own product is favoured when similar third-party products are available.
Section 3

Product evidence to keep for each example

The evidence file should let a reviewer reconstruct the user journey, the comparison group, and the reason each own or third-party result received its position. Keep pre-release and post-release evidence together because small interface, policy, or algorithm changes can create a self-preferencing issue.

Evidence should be specific to the ranking surface. A generic competition-policy memo is not enough if the product change affected crawling priority, index inclusion, feature eligibility, result grouping, default sort order, result-card format, ratings treatment, or a voice-assistant handoff.

  • Surface inventory: the core platform service, affected route or interface, countries or user groups, own services/products on the surface, and similar third-party services/products.
  • Ranking explanation: the parameters, eligibility rules, labels, weights, feature gates, quality signals, policy rules, and manual interventions used to rank, classify, or make results more prominent.
  • Comparison evidence: sampled queries or journeys, own-versus-third-party placements, before/after screenshots, crawl/index logs where relevant, experiment results, and known exceptions.
  • Fairness controls: tests showing that neutral quality, safety, legal, or relevance criteria apply consistently and do not mask preferential treatment for the gatekeeper's own offering.
  • Change record: product requirement document, engineering ticket, legal review, release approval, rollback criteria, monitoring dashboard, and owner for post-release complaints or anomalies.
Section 4

Article 11 reporting linkage

Article 11 connects product evidence to the gatekeeper's formal compliance reporting. Within 6 months after designation, the gatekeeper must provide the Commission with a detailed and transparent report on measures implemented to ensure compliance with Articles 5, 6, and 7, and must publish and provide a non-confidential summary. The report and summary must be updated at least annually.

For self-preferencing examples, do not wait until annual reporting to assemble evidence. Every release that changes ranking, indexing, crawling, or display prominence should produce report-ready material that can be lifted into the Article 11 compliance report, the non-confidential summary, or an annex.

  • Map each Article 6(5) control to the affected core platform service and the specific ranking surface.
  • Maintain a concise explanation of the measure, the implementation date, product/service/device scope, geographic scope, and the pre-release situation it replaced.
  • Keep evidence of customer-experience changes such as interface changes, choice screens, warning messages, system updates, available functionality, and journeys to access functionality.
  • Prepare a non-confidential version that is self-standing enough for third parties to provide meaningful input without exposing protected confidential information.
  • When the compliance report is updated, highlight differences from the previous version, including relevant annex changes.
Section 5

Release-review controls

Build the self-preferencing review into product release gates for search, marketplace, app-store, feed, video, virtual-assistant, and indexing systems. The control should apply before launch, during experiments, when manual boosting rules change, and when a new gatekeeper-owned product enters a ranked surface.

The release owner should block launch or escalate where the team cannot identify similar third-party offerings, cannot explain why the gatekeeper's own result receives its position, or cannot produce neutral criteria that apply to own and third-party products alike.

Does DMA Article 6(5) only apply to classic search-result ranking?

No. The DMA definition of ranking covers relative prominence across listed core platform service types and Recital 52 says ranking includes display, rating, linking, voice results, and one-result experiences. A self-preferencing review should therefore cover search results, marketplace display, app-store placement, social feeds, video recommendations, and virtual-assistant answers when the other Article 6(5) facts are present.

What should a release team save to support Article 6(5) compliance?

Save the affected core platform service and surface, the own and third-party comparison set, ranking or prominence parameters, screenshots or journey samples, before/after results, engineering and policy changes, legal review, release approval, monitoring plan, and the Article 11 report-ready explanation.

  • Trigger: any change to crawling, indexing, ranking signals, result grouping, default sort, prominence labels, recommendations, voice answers, marketplace badges, editorial placement, or feature eligibility.
  • Reviewer set: product owner, ranking or search engineering owner, competition counsel, data or analytics owner, and compliance-report owner.
  • Required question: does the change make a gatekeeper-owned or controlled product easier to discover, more prominent, more trusted, or more likely to be selected than a similar third-party product?
  • Required test: compare own and third-party results across representative journeys, including queries or contexts where the gatekeeper's own product is eligible and where it is not.
  • Post-release monitor: track complaints, ranking anomalies, manual overrides, policy exceptions, and metrics that show own products gaining prominence after the release.
Primary sources

References and citations

digital-markets-act.ec.europa.eu
Referenced sections
  • The template links compliance reporting to technical, customer-experience, remuneration, and terms changes.
"any changes to the customer experience made in connection with the implementation of the measure concerned"
digital-markets-act.ec.europa.eu
Referenced sections
  • Commission page for designated gatekeepers, core platform services, compliance reports, acquisition lists, and consumer profiling reports.
"Gatekeepers are large online platforms that have been designated as such because they provide services to many European users."
eur-lex.europa.eu
Referenced sections
  • Article 2 defines ranking broadly enough to cover presentation, organisation, communication, and single-result experiences.
"ranking means the relative prominence given to goods or services"
eur-lex.europa.eu
Referenced sections
  • Article 11 sets the compliance-report timing, non-confidential summary, and annual update obligation.
"the gatekeeper shall provide the Commission with a report describing in a detailed and transparent manner the measures it has implemented"
eur-lex.europa.eu
Referenced sections
  • Recital 51 gives examples involving online search, app stores, video-sharing platforms, social feeds, marketplaces, and virtual assistants.
"software applications which are distributed through software application stores, or videos distributed through a video-sharing platform"
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