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. The Article 3(2) presumption requires 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, provision of the same service in at least three Member States, at least 45 million monthly active Union end users and 10,000 yearly active Union business users in the last financial year, and those user thresholds in each of the last three financial years.

When all presumptive thresholds are met, the undertaking must notify the Commission without delay and no later than two months after the thresholds are met. A threshold-meeting undertaking can submit sufficiently substantiated rebuttal arguments. The Commission can also designate below the thresholds after an Article 17 market investigation. The 45-working-day designation clock runs after the Commission receives complete information for the standard threshold route, 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 Booking and iPadOS and removed Facebook Marketplace. As of 25 July 2026, the Commission's portal lists seven gatekeepers providing 23 designated core platform services.

A designation, amendment, repeal, or non-designation affects only the undertaking and services named in that decision. For example, Apple's November 2025 notifications for Apple Ads and Apple Maps led to February 2026 decisions not to designate those services; they did not alter Apple's existing designations for other services.

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.

Article 28 requires an independent compliance function. The management body must approve and review the gatekeeper's compliance strategies and policies periodically and at least once a year. Coordinate this governance cycle with the reporting calendar while keeping a distinct legal record for each duty.

Later public milestones have different legal effects. An investigation opens a procedure; preliminary findings state a provisional view; a final non-compliance decision establishes the Commission's finding and may impose a fine. A consultation does not bind gatekeepers. A specification decision may set implementation steps for one named gatekeeper and feature set without creating a deadline for every designated service.

The Commission's March 2025 Apple interoperability decisions include staged implementation dates extending into 2027. Those dates belong in Apple's decision-specific workstream, not a universal DMA calendar. On 23 April 2025, the Commission adopted its first two final non-compliance decisions and fined Apple and Meta. On 23 July 2026, it announced final Google Search and Google Play decisions with two further fines.

Article 53 required the first evaluation report by 3 May 2026 and every 3 years thereafter. The Commission issued COM(2026) 178 on 28 April 2026. It found the DMA remained fit for purpose and did not need revision at that stage. A review conclusion or proposed follow-up does not amend the regulation; a legal change still needs the applicable legislative or delegated process.

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.