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The DMA gatekeeper cockpit: designation, Article 5 matrix, reporting
The DMA cockpit of the Regingada Compliance Suite records your core platform services and the designation status you declare under Art. 3 of the EU Digital Markets Act, then lists the DMA gatekeeper obligations with an Art. 5 status matrix and an Art. 11 report log. It records designation; it does not calculate the thresholds.
- DMA · Art. 3 designation
- Art. 5 matrix · 11 rows
- Art. 11 · report log
- Threshold calculation · not built
- 5 of 10 service types
What are the DMA gatekeeper obligations, and who owes them?
They are conduct rules for each core platform service named in a designation decision. Article 5 bars combining personal data across services without consent, parity clauses, anti-steering and tying; Article 6 adds duties such as no self-preferencing in ranking (6(5)), sideloading (6(4)), uninstalling apps (6(3)) and data portability (6(9)); Article 7 requires messaging interoperability.
Articles 5 to 7 bind only gatekeepers the European Commission has designated, and only for the services listed in its decision (Art. 3(9) of Regulation (EU) 2022/1925); Art. 2(2) names ten core platform service types, from search engines to operating systems. Compliance is due six months later (Art. 3(10)); for messaging, group chats and calls follow after two and four years (Art. 7(2)). Even before designation, splitting services to stay below the thresholds is barred (Art. 13(1)).
Digital Markets Act compliance thus concerns few companies directly; the Commission’s DMA website lists those designated since 6 September 2023. A US reader is more often a business user — app developer, advertiser, seller — or a platform nearing the Art. 3(2) presumption.
From the welcome card to the designation workflow
Open /suite/#dma. Then:
- Confirm the legal notice. First visit only: read the six-part notice, tick the acknowledgement, then ‘Accept & Continue’.
- Pick the DMA card. ‘DMA · Digital Markets Act’ opens the cockpit directly (no quick check); later, use the sidebar item ‘DMA Twin’.
- Add a service. In the sub-navigation ‘DMA · L4’, click ‘CPS Portfolio’: name, one of five categories, role, the boxes for designation (Art. 3) and thresholds (Art. 3(2)), then ‘+ Add service + classify’.
- Read the tier and the duties. Each service gets a chip; ‘Gatekeeper Obligations’ lists the cards the tier triggers.
- Work the gatekeeper sections. ‘Designation Workflow’, ‘Art. 5 Obligations’, ‘Audit Workflow’ and ‘Compliance Report’ are always listed under ‘Designation Status’, but their panels open only once the first service is Designated Gatekeeper or CPS-Major; none has its own address.
Portfolio, workflow, matrix, audits and report log live in this browser’s local storage — clearing site data deletes them; there is no account. See the trust center.
Eight sections, each tied to an article
| Capability | Legal basis | Output |
|---|---|---|
| CPS Portfolio | Art. 2(2), 3 DMA | Tier chip per service, four tiers |
| Gatekeeper Obligations | Art. 5, 6, 7, 9, 11 + 15, 13, 30 | Seven cards from the compliance obligations register (six without messaging); cross-references on Art. 5 and 6 only |
| Designation Status | Art. 3(2), 3(4) | Dates, appeal status, link to the Commission’s list; its tier line always reads ‘Non-Designated (Default)’ |
| Designation Workflow | Art. 3(3)–(5) | Five steps you set by hand; designation date; anniversary |
| Art. 5 Obligations | Art. 5 (rows labelled 5(2)–(8)), 6(5), 7 | 11 rows, four statuses, a justification each |
| Audit Workflow | Art. 8, 11, 13, 15 | Seven audit areas with date and auditor |
| Compliance Report | Art. 11 | Status count; dated log entries |
| Mandate Packages | Art. 5–7, 11, 15 | Law-firm engagement types by tier; descriptions in German |
Designation is declared
Under the DMA designation process of Article 3 the Commission decides; here you declare the result. The designation box gives Designated Gatekeeper, the thresholds box CPS-Major, the provider role in a listed category CPS-Minor; else Non-Designated. The role ‘Gatekeeper (designated)’ alone changes nothing.
Business users read along
Add the gatekeeper’s service, tick the designation box if the Commission’s list names it, and read the DMA gatekeeper obligations that concern you. The role ‘Business user’ changes nothing.
Other acts, cross-referenced
The Art. 5 card points to Art. 26 DSA and Art. 5(1)(c) GDPR; in cross-regulation mapping, 28 of 92 curated links touch the DMA (GDPR 9, DSA 8, AI Act 6, NIS2 5).
One messaging service, before and after designation
A hypothetical US company runs a cloud-storage product and a messaging app that, on its own figures, meets every Art. 3(2) test.
It adds the messenger — ‘Interpersonal communications’, role ‘Core-Platform-Service Provider’, thresholds box ticked — then the storage product, same role, as ‘Cloud-computing service’. The chips read ‘CPS-Major (≥45M EU users)’, shorthand for all Art. 3(2) tests, and ‘CPS-Minor (under thresholds)’. The gatekeeper sections open, no obligation card appears, and the team sets the notification step (Art. 3(3)) to ‘In progress’.
After a hypothetical designation on 15 September 2026, the team removes both services and re-adds the messenger first, designation box ticked, since the first service’s tier governs. Seven cards appear, Art. 7 among them; with the date in step 3, the anniversary reads 2027-09-15.
The team sets eight rows of its DMA Article 5 obligations matrix to Compliant, two to Partial, one to Pending, each justified — its own draft; ‘Compliance Report’ counts them once the view is reopened. Not turned into a date: compliance (Art. 3(10)) and the first Art. 11 and 15 filings, all due mid-March 2027; the team tracks them by hand.
Seven limits of the DMA cockpit
- Thresholds are a checkbox. No field for turnover, market value or users; the three-year and three-Member-State conditions of Art. 3(2) are not asked.
- Five of ten service types. Online intermediation (app stores, marketplaces), operating systems, browsers, virtual assistants and online advertising (Art. 2(2)) are not offered.
- The first service governs. The first service’s tier — not the highest — decides which sections and cards appear; the ‘Designation Status’ header reads ‘Non-Designated (Default)’ in every case.
- Matrix rows are paraphrases. Titles and tags diverge (a ‘5(2)’ row is tagged 5(3)). Rows ‘5(5)’ and ‘5(6)’ describe business-user access and data portability, not end users’ access to content acquired elsewhere (Art. 5(5)) or complaints to authorities (Art. 5(6)); ‘5(8)’ describes app uninstallation (Art. 6(3)); 5(9) and 5(10) have no row. Read each row against the Regulation.
- Only the 12-month date. The six-month deadlines and the three-year review of Art. 4(2) are not computed.
- A log, not a report. The DMA compliance report under Article 11 is written outside the suite; the buttons only add dated entries. A DOCX export needs the deep-analysis engine, which is not part of the browser edition; nothing is sent to the Commission.
- Gaps. No card for Art. 14 or the Art. 28 compliance function; one workflow and matrix per browser, not per service; the obligations subtitle cites outdated article numbers.
Frequently asked questions
How does a company become a designated gatekeeper?
By Commission decision. The Art. 3(2) presumption: in each of the last three financial years, 45 million monthly active end users and 10,000 yearly active business users in the Union, and €7.5 billion Union turnover (or €75 billion average market capitalisation in the last financial year), with the service in at least three Member States. Notification is due within two months (Art. 3(3)), the decision within 45 working days (Art. 3(4)). Below the thresholds, a market investigation can lead to designation (Art. 3(8), 17).
What must a gatekeeper report under Article 11?
A report on the measures taken to comply with Articles 5, 6 and 7, due within six months of designation and updated at least annually, plus a published non-confidential summary (Art. 11 DMA). Art. 15 separately requires an independently audited description of consumer-profiling techniques, also within six months. The cockpit logs dated Art. 11 report entries and dates the Art. 15 audit areas; it drafts neither text.
What is the difference between the DMA and the DSA?
The DMA vs DSA difference lies in whom they address. The DMA sets conduct rules for the few gatekeepers the Commission designates; the DSA sets content and transparency duties for every intermediary service, scaled by tier. One service can fall under both; see the DSA compliance software page.
What does the DMA mean for app developers and other business users?
It sets duties a gatekeeper owes them for its designated services. Business users may promote offers and contract off-platform (Art. 5(4)), price differently elsewhere (5(3)), decline its payment service (5(7)), access the data they generate (6(10)) and get fair access to app stores, search and social networks (6(12)); developers may distribute outside its store (6(4)). Anyone can inform the Commission or a national authority (Art. 27); court remedies depend on national law.
What are the fines under the DMA?
Up to 10% of total worldwide turnover, 20% for repeating the same or a similar infringement within eight years (Art. 30 DMA), and 1% for procedural breaches such as a missed notification (Art. 30(3)). Periodic penalty payments reach 5% of average daily worldwide turnover (Art. 31). Where a market investigation finds systematic non-compliance — deemed after three non-compliance decisions in eight years — the Commission can impose behavioural or structural remedies (Art. 18).
What a designation checkbox cannot decide
Three questions sit behind the two boxes: whether your user counts meet Art. 3(2) under the Annex’s counting rules; whether Art. 3(5) arguments, filed with the notification, could rebut the presumption; and whether a consent flow (Art. 5(2)) or access terms (Art. 6(12)) meet the text as the Commission applies it. Business users ask the mirror question. Regingada UG gives no legal advice; the law firm Theo Funk can assess these under a separate mandate.
The DMA requires no representative in the Union. If the service is also a DSA intermediary service and you have no EU establishment, Art. 13 DSA requires a legal representative — a role Regingada UG (haftungsbeschränkt) takes on under a separate representation contract. Where the GDPR reaches you from abroad, Art. 27 GDPR can require one too.