Summary statistics
Overlaps: 4 · Conflicts: 1 · Gaps: 2
7 article-level crossrefs catalogued between DMA and DSA 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 15 | DSA Art 15 | overlap | medium | [entity affected: gatekeeper / very large online platform] Both regulations require large platforms to publish annual reports on their operations, specifically regarding profiling techniques (DMA) and |
| DMA Art 11 | DSA Art 15 | overlap | medium | [entity affected: gatekeeper / provider of intermediary services] Both regulations mandate the publication of transparency reports or compliance summaries to ensure accountability and public oversight |
| DMA Art 13 | DSA Art 25 | overlap | high | [entity affected: gatekeeper / provider of online platforms] Both regulations prohibit manipulative or deceptive practices, with DMA focusing on undermining compliance and DSA focusing on dark pattern |
| DMA Art 14 | DSA Art 10 | overlap | low | [entity affected: gatekeeper / provider of intermediary services] Both regulations require entities to inform authorities about specific events or data, such as concentrations (DMA) or receipt of info |
| DMA Art 1 | DSA Art 10 | conflict | 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 cre |
| DMA Art ? | DSA Art ? | gap | medium | [entity affected: small and medium-sized online platforms] Neither regulation imposes significant compliance burdens on platforms that do not meet the 'gatekeeper' or 'very large online platform' thre |
| DMA Art ? | DSA Art ? | gap | high | [entity affected: providers of emerging technologies (e.g., AI agents)] Neither regulation explicitly addresses the compliance obligations for autonomous AI agents acting as intermediaries or gatekeep |
Conflicts explained
The 1 article-level conflicts between DMA and DSA mean a control that satisfies one can pull the wrong way on the other:
- DMA Art 1 vs DSA Art 10 — [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.
Which regulation takes precedence
EU law does not lay down a universal precedence rule between DMA and DSA. 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 4 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
- dma obligations digital sector
- dma obligations electronic communications
- dma obligations online advertising
- dma vs dora comparison
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