Technological tools and traditional measures to comply with the DMA: Legal analysis from gatekeepers’ reports under article 11

Abstract

This paper provides an in-depth examination of the technological and governance tools implemented by companies designated as “gatekeepers” under the Digital Markets Act (DMA) to fulfil the extensive ex-ante obligations set forth by the Regulation. Drawing on the (non-confidential summaries of the) compliance reports submitted in 2024 and 2025 by these companies under Article 11, the paper reveals – exploring both legal and technological dimensions – how gatekeepers align with the DMA’s requirements. The study thus highlights the interplay between centralised enforcement by the European Commission, sophisticated technological solutions and robust governance measures required by the DMA, shedding light on both the achievements and challenges of maintaining compliance in rapidly evolving digital markets.