Obligations in scope
Article 5 — gatekeeper
The gatekeeper shall not process personal data of end users using services of third parties that make use of core platform services of the gatekeeper for the purpose of providing online advertising services. Action required: prohibit.
Article 5 — gatekeeper
The gatekeeper shall provide each advertiser, upon request, with information on a daily basis free of charge concerning each advertisement placed, including price, fees, publisher remuneration (subject to consent), and metrics. Action required: provide. Deadline: daily.
Article 5 — gatekeeper
If a publisher does not consent to sharing remuneration information, the gatekeeper shall provide each advertiser free of charge with information concerning the daily average remuneration received by that publisher. Action required: provide. Deadline: daily.
Article 5 — gatekeeper
The gatekeeper shall provide each publisher, upon request, with free of charge information on a daily basis concerning each advertisement displayed, including remuneration, fees, advertiser price (subject to consent), and metrics. Action required: provide. Deadline: daily.
Article 5 — gatekeeper
If an advertiser does not consent to sharing price information, the gatekeeper shall provide each publisher free of charge with information concerning the daily average price paid by that advertiser. Action required: provide. Deadline: daily.
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 5 — prohibit (gatekeeper)
- Art 5 — provide (gatekeeper)
Obligation reference table
| Article | Obligated entity | Deadline | Penalty |
|---|---|---|---|
| Art 5 | gatekeeper | — | — |
| Art 5 | gatekeeper | daily | — |
| Art 5 | gatekeeper | daily | — |
| Art 5 | gatekeeper | daily | — |
| Art 5 | gatekeeper | daily | — |
Penalty exposure
None of the 5 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.
Related Fontvera pages
- dma obligations digital sector
- dma obligations electronic communications
- dma vs dora comparison
- dma vs dsa comparison
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