Where do DMA and DORA overlap?

In 3 article-level pairings recorded in the Fontvera corpus. The table above lists each pair with the specific articles and a plain-language description.

Where do DMA and DORA conflict?

In 0 article-level conflicts. The most concrete ones are summarised in the Conflicts explained section.

Which regulation prevails in a conflict between DMA and DORA?

Neither regulation resolves the conflict on its face. Conflicts are typically resolved by the more specific provision or by regulator guidance — a legal-judgement call, not a mechanical rule.

§ DMA · DORA COMPARISON

DMA vs DORA: Where They Overlap and Conflict

3 overlaps, 0 conflicts and 2 gaps mapped between DMA and DORA in the Fontvera regulatory corpus.

Summary

DMA and DORA both apply across European business activity, but they were drafted at different times with different policy goals. This page summarises every article-level crossref between the two in the Fontvera corpus.

3 overlaps mean the same conduct triggers obligations in both regimes — design controls once, document twice. 0 conflicts mean the two regulations push in opposite directions on a specific question. 2 gaps mean one regulation leaves something on a topic the other addresses.

Who this applies to

Compliance teams who need to map a single control framework onto both DMA and DORA.

Compliance deadline

§ Detail

In depth

Summary statistics

Overlaps: 3 · Conflicts: 0 · Gaps: 2

5 article-level crossrefs catalogued between DMA and DORA 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
DMA Art 11	DORA Art 11	overlap	low	[entity affected: Gatekeepers that are also Financial Entities] Both regulations require annual reporting and updating of compliance or business continuity plans. DMA Art 11 requires gatekeepers to up
DMA Art 15	DORA Art 13	overlap	low	[entity affected: Gatekeepers that are also Financial Entities] Both regulations mandate annual updates or reporting on specific operational aspects. DMA Art 15 requires gatekeepers to update audited
DMA Art 21	DORA Art 17	overlap	medium	[entity affected: Gatekeepers that are also Financial Entities] Both regulations impose obligations to provide information and access to data to authorities. DMA Art 21 requires undertakings to provid
DMA Art ?	DORA Art ?	gap	high	[entity affected: ICT Third-Party Service Providers serving Gatekeepers] DMA focuses on gatekeeper obligations and DORA on financial entities, leaving a gap in direct regulatory oversight for non-fina
DMA Art ?	DORA Art ?	gap	high	[entity affected: Gatekeepers providing financial services] There is no clear coordination mechanism defined between DMA enforcement (Commission) and DORA supervision (National Competent Authorities/E

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:

DMA Art 21 vs DORA Art 17 (medium severity) — [entity affected: Gatekeepers that are also Financial Entities] Both regulations impose obligations to provide information and access to data to authorities. DMA Art 21 requires undertakings to provide necessary information and access to data/algorithms to the Commission, while DORA Art 17 requires financial entities to record and report ICT incidents to competent authorities.
DMA Art 11 vs DORA Art 11 (low severity) — [entity affected: Gatekeepers that are also Financial Entities] Both regulations require annual reporting and updating of compliance or business continuity plans. DMA Art 11 requires gatekeepers to update compliance reports annually, while DORA Art 11 requires financial entities to test and review ICT business continuity plans at least yearly.
DMA Art 15 vs DORA Art 13 (low severity) — [entity affected: Gatekeepers that are also Financial Entities] Both regulations mandate annual updates or reporting on specific operational aspects. DMA Art 15 requires gatekeepers to update audited descriptions of profiling techniques annually, while DORA Art 13 requires senior ICT staff to report yearly to the management body on resilience findings.

Which regulation takes precedence

EU law does not lay down a universal precedence rule between DMA and DORA. 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.