Article 20

Internal complaint-handling system

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Evaluation Scenarios (5 total)

Paragraph 1

Providers of online platforms shall provide recipients of the service, including individuals or entities that have submitted a notice, for a period of at least six months following the decision referred to in this paragraph, with access to an effective internal complaint-handling system that enables them to lodge complaints, electronically and free of charge, against the decision taken by the provider of the online platform upon the receipt of a notice or against the following decisions taken by the provider of the online platform on the grounds that the information provided by the recipients constitutes illegal content or is incompatible with its terms and conditions:

(a) decisions whether or not to remove or disable access to or restrict visibility of the information;
(b) decisions whether or not to suspend or terminate the provision of the service, in whole or in part, to the recipients;
(c) decisions whether or not to suspend or terminate the recipients’ account;
(d) decisions whether or not to suspend, terminate or otherwise restrict the ability to monetise information provided by the recipients.
Obligations (1)
Online platforms must provide recipients with access to an effective internal complaint-handling system for at least six months following certain decisions Priority: 80
1 evaluation scenario
Evaluation Scenarios (1)
1 scenario
Internal complaint-handling system is available and effective for required decisions
dsa-20-1-complaint-system-accessible-v1
Given

An online platform has issued moderation decisions covered by Article 20(1)

When
  • A recipient attempts to lodge a complaint within six months of the decision
Then
  • The complaint system is accessible electronically and free of charge from the decision notice
  • Complaint submission supports referencing the original decision and uploading supporting evidence
  • The platform retains complaints and their outcomes for audit at least six months from submission
Platform Types
all
Paragraph 2

The period of at least six months referred to in paragraph 1 of this Article shall start on the day on which the recipient of the service is informed about the decision in accordance with Article 16(5) or Article 17.

No obligations: This section only provides definitions and background context
Evaluation Scenarios
No evaluation scenarios defined for this paragraph
Paragraph 3

Providers of online platforms shall ensure that their internal complaint-handling systems are easy to access, user-friendly and enable and facilitate the submission of sufficiently precise and adequately substantiated complaints.

Obligations (1)
Online platforms must ensure their complaint systems are accessible, user-friendly and facilitate proper complaint submission Priority: 80
1 evaluation scenario
Evaluation Scenarios (1)
1 scenario
Complaint-handling interface is usable and supports precise submissions
dsa-20-3-complaint-usability-v1
Given

Templates and user interface for internal complaints

When
  • Evaluating the complaint submission form with representative users
Then
  • The form describes required information, accepts structured details, and allows attachments
  • Accessibility checks confirm the form is usable with assistive technologies
  • Confirmation page summarizes submitted information and next steps
Platform Types
all
Paragraph 4

Providers of online platforms shall handle complaints submitted through their internal complaint-handling system in a timely, non-discriminatory, diligent and non-arbitrary manner. Where a complaint contains sufficient grounds for the provider of the online platform to consider that its decision not to act upon the notice is unfounded or that the information to which the complaint relates is not illegal and is not incompatible with its terms and conditions, or contains information indicating that the complainant’s conduct does not warrant the measure taken, it shall reverse its decision referred to in paragraph 1 without undue delay.

Obligations (1)
Online platforms must handle complaints in a timely, non-discriminatory, diligent and non-arbitrary manner, and reverse decisions when complaints have sufficient grounds Priority: 80
1 evaluation scenario
Evaluation Scenarios (1)
1 scenario
Complaint handling is timely, fair, and responsive to valid grievances
dsa-20-4-complaint-processing-standards-v1
Given

A set of internal complaint cases and resolution logs

When
  • Auditing complaint resolutions for compliance with Article 20(4)
Then
  • Resolution times meet the platform's published service levels without discriminatory variance
  • Decisions are reversed when the complaint demonstrates content is lawful or aligned with terms
  • Quality assurance checks or supervisor reviews confirm non-arbitrary outcomes
Platform Types
all
Paragraph 5

Providers of online platforms shall inform complainants without undue delay of their reasoned decision in respect of the information to which the complaint relates and of the possibility of out-of-court dispute settlement provided for in Article 21 and other available possibilities for redress.

Obligations (1)
Online platforms must inform complainants of reasoned decisions and available redress options without undue delay Priority: 80
1 evaluation scenario
Evaluation Scenarios (1)
1 scenario
Complainants receive reasoned decisions and redress information
dsa-20-5-complaint-decision-notification-v1
Given

Complaint decisions generated by the platform

When
  • Communicating the outcome to the complainant
Then
  • Notifications detail the decision, supporting reasoning, and reference Article 21 out-of-court options
  • Delivery timestamps show notifications are sent without undue delay after resolution
  • Records include available redress channels and how to initiate them
Platform Types
all
Paragraph 6

Providers of online platforms shall ensure that the decisions, referred to in paragraph 5, are taken under the supervision of appropriately qualified staff, and not solely on the basis of automated means.

Obligations (1)
Online platforms must ensure complaint decisions are supervised by qualified staff and not made solely through automated means Priority: 80
1 evaluation scenario
Evaluation Scenarios (1)
1 scenario
Complaint decisions involve qualified human oversight
dsa-20-6-human-oversight-v1
Given

Staffing plans and workflows for complaint handling

When
  • Reviewing how complaint decisions are authorized and supervised
Then
  • Appropriately qualified staff review and approve complaint outcomes
  • Automated tools support but do not solely determine final decisions
  • Training records and escalation paths demonstrate ongoing oversight responsibilities
Platform Types
all
Regulations List
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