Summary statistics
Overlaps: 3 · Conflicts: 1 · Gaps: 2
6 article-level crossrefs catalogued between AI Act and DMA from the Fontvera EU regulatory corpus. Article numbers are verbatim from the underlying obligation_crossrefs table; descriptions are extracted, not paraphrased.
All crossrefs between these regulations
| Article (A) | Article (B) | Type | Severity | Description |
|---|---|---|---|---|
| AI Act Art 101 | DMA Art 17 | overlap | low | [entity affected: Commission] Both regulations require the Commission to communicate preliminary findings to the concerned entity (provider or gatekeeper) before adopting final decisions, ensuring pro |
| AI Act Art 101 | DMA Art 18 | overlap | low | [entity affected: Commission] Both regulations mandate that the Commission communicate preliminary findings to the subject of the proceedings (provider or gatekeeper) as part of the enforcement proces |
| AI Act Art 100 | DMA Art 21 | overlap | medium | [entity affected: Union institutions/Undertakings] Both regulations require entities to provide necessary information and access to data or files to the Commission or supervisory authorities during in |
| AI Act Art ? | DMA Art ? | gap | high | [entity affected: Gatekeepers using High-Risk AI] A gatekeeper deploying a high-risk AI system must comply with both AI Act safety requirements and DMA interoperability/fairness obligations, but neith |
| AI Act Art ? | DMA Art ? | gap | high | [entity affected: Providers of General-Purpose AI Models] General-purpose AI models used by gatekeepers may fall under both regulations, but there is no clear guidance on whether DMA's prohibition on |
| AI Act Art 18 | DMA Art 5 | conflict | medium | [entity affected: Gatekeeper/Provider] AI Act requires providers to keep technical documentation and logs for 10 years, while DMA requires gatekeepers to provide real-time access to data and algorithm |
Conflicts explained
The 1 article-level conflicts between AI Act and DMA mean a control that satisfies one can pull the wrong way on the other:
- AI Act Art 18 vs DMA Art 5 — [entity affected: Gatekeeper/Provider] AI Act requires providers to keep technical documentation and logs for 10 years, while DMA requires gatekeepers to provide real-time access to data and algorithms, potentially creating tension between long-term data retention for compliance and immediate data portability/access rights.
Which regulation takes precedence
EU law does not lay down a universal precedence rule between AI Act and DMA. In practice three resolution approaches apply: lex specialis (the more specific provision wins when both purport to govern the same conduct); regulator guidance (EDPB, EBA, ESMA and the AI Office have all issued joint readings on overlapping articles — check the most recent applicable opinion); and document the choice (when the regulations leave the call to the controller, the audit defence is your written reasoning, not the regulator's silence). Where the corpus surfaces a conflict rather than an overlap, treat that as an escalation path to legal — not a control-design question.
What this means for your compliance team
Treat the 3 overlaps as design opportunities — one control, two regulatory anchors. Treat the 1 conflicts as escalation paths to legal: the regulations themselves don't resolve them, you do, and you document the reasoning. The 2 gaps point at scenarios where one regulation is silent while the other speaks — assume the regulator who has the explicit rule will win.
Related Fontvera pages
- ai act art 17 provider obligations
- ai act art 70 commission obligations
- ai act authorized representative
- ai act automotive
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