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:
Upload the terms-of-service section covering complaints and appeals, plus a screenshot of the in-product complaints entry point (form, chat, or email address). The copy should mention (i) how to file, (ii) that EU users can challenge moderation or account decisions up to six months after the decision, and (iii) a link to out-of-court dispute-resolution bodies.
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.
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.
A browser accessing the platform as a logged-out user — standing in for a recipient whose account has been suspended or terminated and who therefore cannot log in to appeal
- We check the platform's Terms and Conditions, help center, or other public-facing policy documents for details on how to submit complaints about enforcement decisions
- Regardless of whether the T&Cs describe a complaint process, we navigate the platform to locate the actual complaint submission mechanism (in-platform form, email address, chat, or other channel)
- We attempt to reach and use the complaint submission route as a logged-out user (as a suspended or terminated user would experience it) and observe whether it is usable or requires signing in
- An appeal/complaint path against enforcement decisions is discoverable from the public surface — through site navigation, the footer, or clear documentation in the T&Cs, help centre, or policy documents
- A user who cannot log in (e.g. because their account has been suspended or terminated) can reach and use a complaint submission route — such as a public webform, a published complaints/appeals email address, or another channel that does not require an active login
- The complaint mechanism is reachable within 3 clicks from the homepage or footer
- The mechanism allows submitting free-text information describing the complaint
- The mechanism allows attaching or including supporting evidence where necessary
Complaint-handling mechanism (in-platform system, email, or external channel) for appealing enforcement decisions is discoverable, accessible, and supports precise submissions — including for users who can no longer log in. Article 20's appeal right exists precisely for recipients whose account has been suspended or terminated, so an appeal path that can only be reached or used while logged in locks out the very population it is meant to serve. Grading note — for this obligation a login-only complaint route is a genuine gap; the second THEN below therefore asserts that a user who cannot authenticate still has a usable, no-login route to submit a complaint. If the only available complaint route requires an active login, that THEN fails and is the observed gap — grade it a fail, do not pass on discoverability alone and do not downgrade to inconclusive. Channel form is not itself the gap — a published no-login email address or external channel satisfies this on equal footing with an in-product webform (Article 20(1) only requires an electronic, free-of-charge route), so do not fail or downgrade a platform merely for using email or an external channel rather than a built-in form. When recommending improvements, include specific draft language the platform could adopt (e.g., suggested help center text, complaint form copy, or T&C clauses).
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.
Upload the complaints-handling policy showing that complaints are handled in a diligent, objective, non-discriminatory, and timely manner. Optionally, attach a terms-of-service section making the same commitments, and a log or redacted sample showing a past decision reversed after a well-grounded complaint — with the time between complaint intake and reversal.
A browser accessing the platform's home page anonymously
- We navigate to the platform's Terms and Conditions, help center, or other public-facing policy documents
- We search for information about how the platform handles complaints about enforcement decisions
- The policy describes the platform's approach to processing complaints (e.g., expected timelines, review process)
- The policy indicates that complaint handling is non-arbitrary and based on objective criteria
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.
Upload one or more of: (a) the complaints-handling policy; (b) a real or template decision-communication message to a complainant; (c) a log extract showing time-to-communicate after a decision. The material should show that complainants receive a reasoned decision and information about out-of-court dispute settlement and other redress options, without undue delay.
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.
A browser accessing the platform's home page anonymously
- We navigate to the platform's complaints-handling or appeals policy (in the Terms and Conditions, help centre, or other public-facing policy documents)
- We read the policy text for statements on how complaint decisions are made
- A complaints-handling policy is publicly available on the platform
- The policy states that appropriately qualified staff supervise decisions on complaints
- The policy states that complaint decisions are not taken solely on the basis of automated means