A seat reserved for John Ternus

Subject: Transmittal of the Platform Fairness Standard, RC/PL/2026/1

Dear Mr Ternus,

1.I write on behalf of the Platform Council of Reseated to transmit the Platform Fairness Standard adopted by the Founders Assembly on 13 August 2026 as RC/PL/2026/1. The Standard is attached to this letter. It sets out minimum procedural protections for small businesses when a platform suspends an account, removes a listing, holds a payout or changes a fee.

2.Reseated is a global assembly of small-business owners, organized in seven councils. Its Founding Secretariat is in the United States. I serve as Advisory Council Chair of Reseated Councils. The Assembly adopted its Charter on 10 February 2026 and its Rules of Procedure by ballot on 19 March 2026. The Platform Council’s work follows a defined process: reports are assessed against a five-part pattern test; a draft response is prepared; members and the public are consulted; the Assembly votes; and letters are sent to the chief executives who can adopt the proposed practice. The Assembly is a nonprofit.

3.This process is intended to make the request both accountable and practical. It does not treat an individual account dispute as proof of a general failure, nor does it claim that every platform or every country presents the same circumstances. It asks whether reported experiences show a repeated pattern, and then proposes a general safeguard proportionate to that pattern. Members are anonymous

unless they choose a public seat. Their evidence is considered in aggregate; this letter does not identify a member or any member’s business.

The Assembly’s decision

4.The Platform Fairness Standard was adopted after a public consultation and an Assembly ballot. It asks platforms to provide four basic protections before taking a covered action:

1. Written notice to the affected business.

2. A specific reason for the proposed or completed action, sufficient for the business to understand the issue and respond.

3. Access to review by a person, rather than a process that leaves the business without a meaningful human review.

4. A defined time limit for a payout hold.

5.The protections apply to account suspension, listing removal, payout holds and fee changes. The Standard also asks that the same protections be made available in every country in which the platform operates. It does not prescribe a single commercial outcome in an individual case. It establishes a fair process through which the platform can explain an action and the business can seek review.

6.The Assembly adopted the Standard by 86.4 per cent of votes cast, with 58 per cent turnout. The vote followed consultation on the draft and a revised text. These figures are included to make the mandate clear: this is an adopted Assembly resolution, not a proposal issued in my personal capacity. The Assembly’s request is for Apple to consider the text as a whole and to state whether it will implement it.

Evidence and the pattern identified

7.As of 20 August 2026, Reseated had 1,366 members seated in 49 countries and had received 4,065 reports from 50 countries. The Platform Council comprised 410 members from 48 countries and had received 1,764 reports from 50 countries. The Council’s reports concern the experience of small businesses using platforms; they do not, by themselves, establish a legal violation by any named company.

8.The evidence is international in reach. Among the countries with the largest numbers of Platform Council reports were the United States, 210; Brazil, 101; Germany, 101; Mexico, 95; the Philippines, 91; Spain, 88; the United Kingdom, 82; and France, 81. These figures show reports from the Americas, Europe and Asia-Pacific. They are country counts, not regional totals, and should not be read as a complete breakdown of all 50 countries. The evidence is not confined to one national market or one legal system.

9.The reported situations include 990 reports concerning account suspension and 774 concerning funds held. These categories describe reported situations and are not necessarily mutually exclusive. The median amount at stake in Platform Council reports was approximately US$4,107. For a small business, a restriction on access to an account or a delay in receiving earned funds can affect the ability to pay suppliers, meet payroll, purchase stock or continue trading. The amount at stake is not a measure of the full downstream impact on a business.

10.The pattern test used by Reseated examines Volume, Frequency, Consistency, Spread and Corroboration. Volume asks whether reports are numerous enough to merit a collective response. Frequency considers whether the events recur over time. Consistency asks whether independent accounts describe materially similar problems. Spread examines whether the pattern appears across places or groups, rather than in a single isolated setting. Corroboration

considers whether the accounts are supported by relevant records or other evidence. The Platform Council certified that PL-001 met all five tests before drafting the Standard.

11.This test is a method for deciding whether to propose a system-level safeguard. It is not a finding about the conduct of Apple, and the report totals cited here are not attributed to Apple. Reseated has not assessed these figures as a company-specific count, and this letter makes no claim about Apple’s individual decisions, internal processes, numbers or legal cases. The relevant point is narrower: small businesses in many countries have reported recurring difficulties around account access, listing status and payout availability, and they have asked for understandable notice, reasons, human review and a time limit.

12.The broader economic context reinforces why clear process matters. The United Nations estimates that micro-, small- and medium-sized enterprises represent about 90 per cent of businesses, 60–70 per cent of employment and around 50 per cent of GDP worldwide.¹ The International Labour Organization estimates that MSMEs account for about 70 per cent of employment worldwide and that about 80 per cent operate in the informal economy.² These global estimates do not describe any individual Reseated member or prove a particular platform practice. They do show why predictable rules for small businesses are a matter of broad economic consequence.

Relationship to existing legal frameworks

13.The Standard is designed as a consistent baseline for platform-business interactions across countries. It recognizes that legal requirements differ by jurisdiction and does not purport to replace them. Where legislation already sets relevant protections, the Standard’s approach is aligned with the direction of those protections; where the law is narrower, the Assembly’s request is that a platform voluntarily extend a coherent process across its operations.

14.In the European Union, the Platform-to-Business Regulation requires a provider that restricts or suspends a business user to provide a statement of reasons. It also establishes a minimum notice period before termination of the whole service, subject to the Regulation’s provisions and exceptions.³ The Digital Services Act requires providers to give statements of reasons for specified moderation decisions, including information about whether automated means were used in taking the decision.⁴ These instruments provide relevant reference points for notice and reasons. The Standard’s additional request for human review and a defined limit on payout holds is stated as a practical baseline; this letter does not suggest that those exact requirements are imposed in every circumstance by the cited EU provisions.

15.Japan’s Act on Improving Transparency and Fairness of Specified Digital Platforms provides another relevant case. The Act applies to designated platforms and includes disclosure requirements concerning terms and conditions, including conditions relating to withholding payments.⁵ Its scope is determined by the Act and the applicable designations. This letter does not assert that Apple or any particular Apple service is covered by the Act. The relevance here is that transparency around payment conditions has been recognized as an appropriate subject for platform governance.

16.Apple operates platforms used by small businesses in many countries. The Assembly therefore asks Apple to assess the Standard against the range of markets in which those businesses rely on its platforms, while taking account of applicable local law. The request is not that a company disregard jurisdiction-specific obligations. It is that a business should not lose basic procedural protection solely because it is operating in a different country.

Requests to Apple

17.The Platform Council respectfully asks you, as Chief Executive Officer, to consider and respond to the following requests:

1. Accept the Platform Fairness Standard, RC/PL/2026/1, as a company-wide baseline for the covered actions affecting small-business users of Apple platforms.

2. Provide written notice before an account suspension, listing removal, payout hold or fee change takes effect, except where immediate action is required by applicable law or a documented urgent risk. Where prior notice is not practicable, provide notice as soon as reasonably possible afterwards.

3. Give the affected business a specific, intelligible reason for the action and identify the relevant requirement, transaction or conduct sufficiently for the business to understand what is at issue. A generic notice that does not enable a response would not meet the purpose of this request.

4. Make available review by a person with authority to reconsider the action. The review should allow the business to provide relevant information and should not simply repeat an automated outcome without meaningful consideration.

5. Set a clear maximum duration or review point for any payout hold, communicate that limit to the affected business, and explain the steps by which the hold may be resolved. This request does not require release of funds that must lawfully remain withheld; it asks for a defined process and a time-bound review.

6. Apply these protections consistently across the countries in which the relevant platforms operate, while meeting any stronger local legal requirement and explaining any necessary, narrowly defined local exception.

7. Publish or provide a written statement describing whether Apple accepts the Standard, any implementation timetable, and any material exception it considers necessary. If Apple does not accept a provision, the Assembly asks that the response identify the provision and give the reason, so the members can understand the decision.

18.These requests are directed to process, not to a predetermined result in any specific account matter. They do not ask Apple to disclose confidential security measures, personal information or individual case files publicly. Nor do they prevent a platform from taking proportionate action where necessary. They ask that the affected business receive a reasoned and reviewable process, subject to lawful limits.

The reserved seat and response process

19.A CEO seat has been reserved for Apple in the Platform Council’s record of the companies asked to consider the Standard. The seat is an invitation to engage with the Assembly’s adopted text. It is not a claim that Apple has accepted the Standard, endorsed Reseated or entered into a commitment.

20.If you choose to accept, the seat may be recorded as signed when Apple provides a written acceptance of the Standard through an authorized representative. The acceptance may state any implementation timetable or qualification that Apple considers necessary. Reseated will record the status and the text of the commitment accurately; it will not describe a partial response as full acceptance. The seat is tracked through the same public status sequence used for the other CEO seats: Proposed, Letter sent, Delivered, Replied, Signed or Empty chair. These labels describe the state of engagement, not a judgment about the company.

21.As of the date of this letter, the seat is recorded as Letter sent. Delivery has not yet been confirmed in this record, and no reply or signature is recorded. If a reply is received, Reseated will publish it in

full, subject to any lawful requirement to withhold personal or confidential material and with any such limitation identified. We will not summarize a response in a way that changes its meaning. If no response is received, the record will state that neutrally; silence will not be presented as agreement or as evidence of a particular motive.

22.We offer to share anonymized and appropriately aggregated Platform Council data to assist Apple’s consideration of the Standard. Any such sharing would be limited to information that does not identify members or their businesses. Reseated can also provide the consultation record and the adopted resolution so that your team can assess both the evidence and the Assembly’s reasoning.

23.The Assembly understands that a global platform must operate across different legal systems and operational contexts. That complexity is a reason to establish a clear baseline and a transparent process, not a reason to leave small businesses without a usable explanation when an important decision affects their ability to trade. We hope Apple will join the Assembly in making those protections predictable.

Sources

1. United Nations, Micro-, Small and Medium-sized Enterprises Day.

2. International Labour Organization, Micro, Small and Medium Enterprises.

3. Regulation (EU) 2019/1150, Article 4.

4. European Commission, Digital Services Act: Transparency Database questions and answers.

5. Japan Act on Improving Transparency and Fairness of Specified Digital Platforms; Ministry of Economy, Trade and Industry, Digital Platforms.

Notes and sources

Sources

1. United Nations, Micro-, Small and Medium-sized Enterprises Day
2. International Labour Organization, Micro, Small and Medium Enterprises
3. Regulation (EU) 2019/1150, Article 4
4. European Commission, Digital Services Act: Transparency Database questions and answers
5. Japan Act on Improving Transparency and Fairness of Specified Digital Platforms
6. Ministry of Economy, Trade and Industry of Japan, Digital Platforms