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Article 20

Internal complaint-handling system

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Evaluation Scenarios (4 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 enforcement decisions, such as restrictions, suspensions, termination. The six months period starts when the decision was communicated to the reporter. Priority: 80
Evaluation Scenarios
No evaluation scenarios defined for this paragraph
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 system (whether in-platform, an email, or external system) is usable and supports precise submissions
dsa-20-3-complaint-usability-v1
Given
  • Only if the platform decided to build an in-platform complaint-handling system (this is not mandatory under the law)
  • A browser accessing the platform's home page as a regular user
When
  • We navigate to the complaint submission form
  • We inspect the form fields, instructions, and accessibility features
Then
  • The navigation to the complaint form is easy to find (no more than 3 clicks from homepage or footer).
  • The form allows submitting information, and allows uploading attachments
  • Accessibility checks confirm the form is usable with assistive technologies
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. Decisions are reversed if proven wrong.
dsa-20-4-complaint-processing-standards-v1
Given

Access to the platform's internal complaint management system and audit dashboard

When
  • We review a sample of complaint resolution logs
  • We review complaint handling policy
Then
  • Decisions on complaints are made within 1 week.
  • Policy of complaint handling is non-arbitrary, fact-based, non-discriminatory.
  • Some log entries indicate that an enforcement decision has been revoked as the result of a complaint, according to the policy.
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 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

Access to the platform's complaint notification templates and delivery logs

When

We review notification templates and delivery records for complaint decisions

Then
  • Notifications detail the decision, supporting other redress options
  • Delivery timestamps show notifications are sent without undue delay after resolution (typically within 24-48 hours)
  • Notifications include available redress channels and instructions on 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 policy includes human-in-the-loop in decision making about the complaint
dsa-20-6-human-oversight-v1
Given

Access to the policy knowledge base for the platform

When

We search for the operating procedures related to handling complaints.

Then

The complaint policy clearly specifies that handling complaints must be done with a human in the loop.

Platform Types
all
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