How many DMA obligations apply to electronic communications?

9 obligations in the Fontvera corpus map to electronic communications under DMA. The breakdown above lists the most concrete 7 of them.

Does DMA conflict with any other EU regulation for electronic communications?

Yes — at least 5 explicit conflicts in the corpus, including AI Act Art 18 vs DMA Art 5.

§ DMA BRIEFING

DMA Obligations for Electronic communications

9 obligations from DMA mapped to electronic communications. Articles, deadlines, and penalties — extracted verbatim from the Regulation.

Summary

DMA sets 9 obligations that apply to electronic communications. This page lists them with article references, obligated-entity language, and penalties — extracted verbatim from the Regulation, not paraphrased.

Use the obligation table and breakdown to scope a compliance programme. The cross-regulatory conflicts section surfaces places where this regulation pulls against neighbouring EU frameworks for the same sector.

Who this applies to

Companies operating in electronic communications that fall within DMA's scope.

Compliance deadline

Mixed timelines — see obligations below.

§ Detail

In depth

Obligations in scope

Article 7 — gatekeeper

Gatekeepers providing listed number-independent interpersonal communications services must make basic functionalities interoperable with other providers' services in the Union by providing necessary technical interfaces free of charge upon request. Action required: make interoperable. Deadline: upon request.

Article 7 — gatekeeper

Gatekeepers must make end-to-end text messaging and file sharing between two individual end users interoperable following the listing in the designation decision. Action required: make interoperable. Deadline: following the listing in the designation decision.

Article 7 — gatekeeper

Gatekeepers must make end-to-end text messaging within groups and file sharing between group chats and individual users interoperable within 2 years from designation. Action required: make interoperable. Deadline: within 2 years from the designation.

Article 7 — gatekeeper

Gatekeepers must make end-to-end voice and video calls between individuals and between group chats and individual users interoperable within 4 years from designation. Action required: make interoperable. Deadline: within 4 years from the designation.

Article 7 — gatekeeper

Gatekeepers must preserve the level of security, including end-to-end encryption where applicable, provided to their own end users across interoperable services. Action required: preserve.

Article 7 — gatekeeper

Gatekeepers must publish a reference offer laying down technical details, general terms, and security levels for interoperability within the period laid down in Article 3(10) and update it where necessary. Action required: publish. Deadline: within the period laid down in Article 3(10).

Article 7 — gatekeeper

Gatekeepers must comply with any reasonable request for interoperability by rendering the requested basic functionalities operational within 3 months after receiving the request. Action required: comply. Deadline: within 3 months after receiving that request.

Practical steps

What the obligations on this page actually require you to do, ordered by article. Use this as a starting checklist; verify each item against the underlying article text before treating it as legal advice.

Art 7 — make interoperable (gatekeeper)
Art 7 — preserve (gatekeeper)
Art 7 — publish (gatekeeper)
Art 7 — comply (gatekeeper)
Art 7 — collect and exchange (gatekeeper)
Art 7 — take measures (gatekeeper)

Obligation reference table

Article	Obligated entity	Deadline	Penalty
Art 7	gatekeeper	upon request	—
Art 7	gatekeeper	following the listing in the designation decision	—
Art 7	gatekeeper	within 2 years from the designation	—
Art 7	gatekeeper	within 4 years from the designation	—
Art 7	gatekeeper	—	—
Art 7	gatekeeper	within the period laid down in Article 3(10)	—
Art 7	gatekeeper	within 3 months after receiving that request	—
Art 7	gatekeeper	—	—
Art 7	gatekeeper	—	—

Penalty exposure

None of the 9 obligations on this page carry an explicit penalty figure in the DMA text itself — the fine ceiling is set elsewhere in the regulation and applies by reference. Refer to DMA's general penalties article (or the diagnostic below) to estimate exposure before signing off on a compliance programme.

Cross-regulatory conflicts

DMA interacts with other EU regulations in ways that can pull compliance teams in opposite directions. The most concrete conflicts in the Fontvera corpus involving this regulation:

AI Act Art 18 ↔ DMA Art 5 (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 algorithms, potentially creating tension between long-term data retention for compliance and immediate data portability/access rights.
DMA Art 1 ↔ GDPR Art 6 (medium) — [entity affected: Member States] DMA prohibits Member States from imposing further obligations on gatekeepers to ensure contestable markets, which may conflict with GDPR's allowance for Member States to introduce specific provisions for lawful processing under public interest or legal obligations.
DMA Art 1 ↔ DSA Art 10 (high) — [entity affected: gatekeeper] DMA Art 1 prohibits Member States from imposing further obligations on gatekeepers, while DSA Art 10 allows Member States to issue orders for information, potentially creating a conflict if a gatekeeper is also a DSA entity.
DMA Art 1 ↔ Data Act Art 14 (high) — [entity affected: Member States] DMA Art 1 prohibits Member States from imposing further obligations on gatekeepers, while Data Act Art 14 imposes specific data sharing obligations on data holders (which may include gatekeepers) for public interest tasks, potentially creating a conflict if interpreted as a 'further obligation' under DMA.
DMA Art 1 ↔ ePrivacy Directive Art 15 (high) — [entity affected: Member States] DMA prohibits Member States from imposing further obligations on gatekeepers to ensure contestable markets, while ePrivacy allows Member States to restrict rights for national security or public security, potentially creating overlapping or contradictory enforcement scopes for gatekeepers.