Artifact GuideEU

EU Digital Markets Act (DMA) Timeline & Key Milestones

A practical, date-driven view of DMA application, designation, compliance, and enforcement.

Designed for planning: convert milestones into release-train deadlines, reporting cadence, and evidence capture checkpoints.

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Author

Sorena AI

Published

Feb 21, 2026

Updated

Feb 23, 2026

Sections

Structured answer sets in this page tree.

Primary sources

Cited legal and guidance references.

Publication metadata

Sorena AI

Published Feb 21, 2026

Updated Feb 23, 2026

Overview

DMA timelines matter because the obligations in Articles 5-7 are anchored to designation decisions per core platform service (CPS). This timeline combines regulation-level dates (application and evaluation), designation milestones (who was designated and when), and obligation-level clocks (6-month compliance, Article 7 staged interoperability deadlines).

Section 1

Regulation-level milestones (application + evaluation cycle)

The DMA has a general application date and an evaluation cycle that can drive future updates (including changes to CPS categories or obligations).

Use these dates to plan "policy refresh" sprints and periodic risk reviews even if your CPS was designated earlier.

1 Nov 2022: certain provisions applied earlier (including delegated-act powers for methodology adjustments).
2 May 2023: DMA applies (general application date).
3 May 2026: Commission must evaluate and report on the DMA, and subsequently every 3 years.

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Section 2

Designation milestones (public anchor dates)

Designation happens per undertaking and results in a decision listing relevant CPS. The Commission publishes and updates a list of gatekeepers and their listed CPS on an ongoing basis.

These public dates are useful for benchmarking program maturity and anticipating follow-on actions (specification, monitoring, enforcement).

6 Sep 2023: first gatekeeper designations (examples include Alphabet, Amazon, Apple, ByteDance, Meta, Microsoft).
29 Apr 2024: Apple designated for iPadOS (operating system for tablets).
13 May 2024: Booking designated for its online intermediation service (Booking.com).
23 Apr 2025: Meta undesignated for its online intermediation service Facebook Marketplace (example of status changes over time).
5 Feb 2026: the Commission found Apple Ads and Apple Maps should not be designated under the DMA after Apple notified them in Nov 2025.

Section 3

The core implementation clock: designation -> 6-month compliance

For implementation teams, the most important DMA timeline is: "CPS listed in designation decision" -> "6 months to comply with Articles 5, 6, and 7."

This clock is CPS-specific: different services can have different listing dates and therefore different compliance due dates.

If thresholds are met, the undertaking must notify the Commission within 2 months after thresholds are met.
The Commission must designate at the latest within 45 working days after receiving complete information.
The gatekeeper must comply with Articles 5-7 within 6 months after the CPS is listed in the designation decision.

Section 4

Interoperability milestones: Article 7 staged deadlines (0 / 2 years / 4 years)

Article 7 introduces staged interoperability obligations for number-independent interpersonal communications services (NICS) listed in the designation decision.

Plan these as multi-year engineering programs with security assurance, abuse prevention, operational monitoring, and partner onboarding.

After listing: 1:1 end-to-end text messaging interoperability; 1:1 file sharing interoperability (where applicable).
Within 2 years: group messaging interoperability and group-to-individual file sharing interoperability.
Within 4 years: voice/video calling interoperability (1:1 and group-to-individual).
Operational SLA: comply with a reasonable interoperability request within 3 months; publish a reference offer within the 6-month compliance period.

Section 5

Enforcement and specification milestones (what triggers changes mid-flight)

The DMA enforcement lifecycle often involves information requests, monitoring, and, where needed, specification decisions under Article 8 for obligations susceptible of further specification.

Treat enforcement events as signals that "implementation expectations" can become more concrete over time; build your program to adapt without major rewrites.

Specification decisions can clarify measures required to achieve effective compliance (example: Article 6(7) interoperability specifications for iOS and iPadOS).
Preliminary findings are an enforcement step that can precede a non-compliance decision (example: Commission preliminary findings on a "pay or consent" model referenced to Article 5(2)).
Monitoring can involve document retention requirements and independent experts or auditors; design evidence capture as a continuous process.
A systematic non-compliance market investigation under Article 18 can lead to behavioral or structural remedies if the Commission sees repeated infringements and continued gatekeeper power.

Section 6

How to use this timeline in your DMA program

A good DMA timeline is not a history lesson - it is a delivery plan. Convert each milestone into owners, outputs, and evidence requirements.

If you operate in a gatekeeper ecosystem (as a business user), use the same timeline to set expectations for platform partners and to plan migration options (portability tools, alternative app stores, interoperability requests).

Create a "CPS-by-CPS" roadmap: designation date, 6-month compliance due date, reporting cycles, and expected specification/enforcement touchpoints.
Run quarterly "DMA delta" reviews: what changed in gatekeeper lists, compliance reports, specification decisions, and enforcement posture.
Maintain a living evidence library aligned to the Commission's Article 11 compliance report template and to the obligations in Articles 5-7.

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