Summary statistics
Overlaps: 3 · Conflicts: 0 · Gaps: 2
5 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 |
Overlaps explained
No conflict-type crossrefs were catalogued for this pair, but the 3 overlaps below mean a single control can be designed to satisfy both regulations at once. Plan the controls jointly to avoid duplicate effort:
- AI Act Art 100 vs DMA Art 21 (medium severity) — [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 investigations or proceedings.
- AI Act Art 101 vs DMA Art 17 (low severity) — [entity affected: Commission] Both regulations require the Commission to communicate preliminary findings to the concerned entity (provider or gatekeeper) before adopting final decisions, ensuring procedural fairness.
- AI Act Art 101 vs DMA Art 18 (low severity) — [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 process.
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 0 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
Check your full compliance exposure with the 5-minute Fontvera diagnostic →