EU Digital Markets Act Timeline and Key Milestones

The DMA was adopted on 14 September 2022 and published in the Official Journal on 12 October 2022. It entered into force on 1 November 2022, 20 days after publication. Entry into force did not mean that every substantive gatekeeper duty applied on that date.

Most provisions applied from 2 May 2023. The regulation separately made Article 3(6) and (7) and Articles 40 and 46 to 50 applicable from 1 November 2022, while Articles 42 and 43 applied from 25 June 2023. A roadmap should preserve those distinctions instead of describing 1 November 2022 as the start of all DMA compliance duties.

The operational DMA calendar starts separately for each candidate core platform service. When all Article 3(2) presumptive thresholds are met, the undertaking must notify the Commission without delay and no later than two months after the thresholds are met. The 45-working-day designation clock runs after the Commission receives complete information, not automatically from a company's internal threshold calculation.

A designation decision lists the core platform services covered for that gatekeeper. Article 3(10) then gives the gatekeeper six months to comply with Articles 5, 6, and 7 for those listed services. Meeting a threshold is therefore not the same event as designation, and designation of one service does not make every product in the corporate group subject to every obligation.

On 6 September 2023, the Commission designated the first six gatekeepers: Alphabet, Amazon, Apple, ByteDance, Meta, and Microsoft. Their initially listed services reached the six-month compliance point in March 2024. Later decisions added or removed specific services and added Booking as a gatekeeper, so teams should use the current Commission case record rather than assuming the first list remains complete.

A designation, amendment, or repeal affects the undertaking and core platform services named in that decision. It is evidence of the DMA's operation, but it does not itself create the same deadline for an unrelated platform.

The six-month implementation point also anchors recurring evidence work. Under Article 11, the gatekeeper must provide a detailed and transparent compliance report and a non-confidential summary within six months after designation, then update both at least annually. Article 15 separately requires an independently audited description of consumer-profiling techniques within six months after designation and an annual update.

The compliance function is not only a filing team. Article 28 requires an independent compliance function, and the management body must approve and review the gatekeeper's compliance strategies and policies periodically and at least once a year. These annual cycles should be coordinated but kept as distinct legal records.

Later public milestones do not all have the same legal effect. A preliminary finding is not a final non-compliance decision. A consultation is not binding guidance. A Commission specification decision may set implementation steps for a named gatekeeper and feature set without creating a general deadline for every designated service.

For example, the Commission's March 2025 Apple interoperability material records specification decisions and staged implementation dates extending into 2027. Those dates belong in Apple's decision-specific workstream, not in a universal DMA calendar. Separately, Article 53 required the first evaluation report by 3 May 2026 and every three years thereafter; review findings or possible follow-up work do not amend the regulation by themselves.

A usable DMA roadmap should let a reviewer reconstruct why a date exists. Do not copy the public timeline into a project plan without connecting each entry to the undertaking, service, decision, trigger, owner, and evidence package.

The minimum calendar record should identify whether the date is fixed by the regulation, calculated from an event, recurring, or imposed in a Commission decision. That classification prevents historical dates and another gatekeeper's deadlines from becoming false requirements in your program.