Article 20

Internal complaint-handling system

Evaluation Scenarios (2 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. Critical Priority
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 Critical Priority
1 evaluation scenario
Evaluation Scenarios (1)
1 scenario
Complaint-handling mechanism (in-platform system, email, or external channel) is discoverable, accessible, and supports precise submissions. When recommending improvements, include specific draft language the platform could adopt (e.g., suggested help center text, complaint form copy, or T&C clauses).
Given

A browser accessing the platform's home page as a regular user

When
  • 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)
Then
  • The complaint mechanism is easy to find, either through intuitive site navigation or through clear documentation in the T&Cs or policy documents
  • 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
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 (2)
Online platforms must handle complaints in a timely, non-discriminatory, diligent and non-arbitrary manner Critical Priority
1 evaluation scenario
Online platforms must reverse enforcement decisions without undue delay when complaints contain sufficient grounds showing the original decision was unfounded Critical Priority
Evaluation Scenarios (1)
1 scenario
The platform's public policies describe complaint processing standards including timeliness, fairness, and objectivity. When recommending improvements, include specific draft policy language the platform could adopt (e.g., suggested complaint handling policy text, timelines, or fairness criteria wording).
Given

A browser accessing the platform's home page anonymously

When
  • 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
Then
  • 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
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 Critical Priority
Evaluation Scenarios
No evaluation scenarios defined for this paragraph
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 Critical Priority
Evaluation Scenarios
No evaluation scenarios defined for this paragraph