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Platform Council
Letter to Enrique Lores, Chief Executive Officer, PayPal, transmitting the Platform Fairness Standard
From: Robert Nikic, Advisory Council Chair, Reseated Councils
To: Enrique Lores, Chief Executive Officer, the payment provider
Subject: Transmission of the Platform Fairness Standard, RC/PL/2026/1
Dear Mr Lores,
1.I write on behalf of the Platform Council of Reseated’s Founders Assembly to transmit the Platform Fairness Standard, adopted by the Assembly on 13 August 2026 as RC/PL/2026/1. The Standard is enclosed with this letter. We invite the payment provider to review it and to sign a public commitment to apply its protections consistently to the small businesses that use the platforms it operates.
2.Reseated is a global assembly of small-business owners, organized in seven councils. It began on 10 February 2026. The Assembly’s work is based on reports from members, public consultation, and a ballot. Members remain anonymous unless they choose to occupy a public seat. Reseated is a nonprofit; it is not a regulator, court, or substitute for any applicable law.
3.The Platform Council addresses recurring practices affecting small businesses that use digital platforms. Its mandate is not to decide individual disputes or to make findings about any particular company. It is to identify patterns across reports, consult on practical standards, and ask the leaders able to adopt those standards to do so. This letter makes no allegation or finding about the payment provider’s individual practices, decisions, performance, or legal compliance.
The evidence and the Assembly’s process
4.The Assembly’s process for each proposed standard is structured: reports are assessed against a five-part pattern test—volume, frequency, consistency, spread, and corroboration—before a draft is prepared. The draft is then opened to public consultation and put to an Assembly ballot. If adopted, letters are sent to the chief executives able to adopt the requested practice. The resulting seats are tracked by procedural status: Proposed, Letter sent, Delivered, Replied, Signed, or Empty chair.
5.PL-001 concerned account suspensions, listing removals, payout holds, and fee changes. The Platform Council certified on 12 May 2026 that the issue met all five parts of the pattern test. The Council published a draft on 26 May, consulted from 2 June to 2 July, and received 487 comments. Following revision, the Assembly adopted the Standard on 13 August, with 86.4 per cent voting in favour and 58 per cent turnout.
6.At the Assembly’s 20 August reporting point, the Platform Council had 410 members in 48 countries and had received 1,764 reports from 50 countries. Those figures are a snapshot of submitted reports, not an estimate of the prevalence of any practice in the full population of businesses. They do not establish the facts of any individual case, and they should not be read as a company-specific count.
7.The reports show an international pattern. Among the countries with the highest report counts were the United States (210), Brazil (101), Germany (101), Mexico (95), the Philippines (91), Spain (88), the United Kingdom (82), and France (81). The following table groups those published country figures geographically. The subtotals add only the named countries in each row; they are not regional totals.
| Geographic grouping | Countries represented in the listed cases | Reports in those countries |
|---|---|---|
| Americas | United States, Brazil, Mexico | 406 |
| Geographic grouping | Countries represented in the listed cases | Reports in those countries |
|---|---|---|
| Europe | Germany, Spain, United Kingdom, France | 352 |
| Geographic grouping | Countries represented in the listed cases | Reports in those countries |
|---|---|---|
| Asia-Pacific | Philippines | 91 |
8.Across the Platform Council’s reports, members recorded 990 situations involving an account suspension and 774 involving funds held. These are report-category counts, not verified determinations about platform conduct. A report may describe a consequential interruption to a business’s ability to trade or access money, but Reseated does not infer from a count alone that a platform acted improperly. The policy question is narrower: whether minimum, understandable procedures can reduce avoidable uncertainty and give affected businesses a meaningful route to seek review.
9.The Council’s evidence also describes businesses of different sizes. In the 20 August snapshot, 37 per cent of reporting members described their team as just themselves, 42 per cent as two to nine people, 17 per cent as ten to forty-nine, and 4 per cent as fifty to 249. The median amount reported at stake was approximately US$4,107. These figures help explain why a delayed payout or an unexplained account restriction may have practical consequences for a small firm. They do not tell us what happened in any one case, and members’ businesses are not identified in this letter.
10.The Council’s five-part assessment was intended to distinguish a recurring issue from an isolated account of harm. Volume and frequency consider how often reports arise; consistency asks whether materially similar problems recur; spread considers whether the issue appears across countries and business circumstances; corroboration considers support for the accounts. Passing the test supports bringing a proposal to consultation. It is not a finding that every report is
proven, that all platforms use the same procedures, or that a particular recipient has engaged in a given practice.
What the Standard asks
11.The Standard asks a platform, before an account suspension, listing removal, payout hold, or fee change, to provide the affected business with written notice and a specific reason; provide review by a person; and set a time limit on payout holds. It asks that these protections apply in every country in which the platform operates, rather than being available only to businesses in selected markets.
12.The Standard is a practical commitment, not a claim that every action must be delayed or that a platform may never respond urgently to a genuine risk. The essential request is for a clear explanation and a usable process. Where immediate action is necessary, the business should still receive a reason and a route to human review as soon as practicable. A time limit on a hold should make clear how long it may continue and what review or information is needed to resolve it. The adopted text sets out the operative commitments; this letter does not amend or replace it.
13.Written notice gives the business a record it can understand and act on. A specific reason is more useful than a general statement that a rule has been violated. Human review gives a business a way to explain context, correct a mistake, or provide requested material. A defined limit on a payout hold helps the business understand when the issue will be reconsidered. Applying the protections across markets makes the commitment easier to explain and reduces uncertainty for businesses operating across borders.
Relationship to existing legal frameworks
14.The Standard is designed to align with procedural protections reflected in existing legal frameworks, while asking for a consistent commitment across countries. In the European Union, the Platform-to-Business Regulation provides for a statement of reasons when an online intermediation service restricts or suspends a business user, and sets a notice period for terminating the whole service, subject to the Regulation’s scope and terms.1 The Standard’s requirement for a specific written reason is consistent with that approach. Its request for human review, defined payout-hold limits, and consistent treatment across countries expresses a broader operational commitment; it should not be taken as a statement that those requirements are identical to the Regulation.
15.Article 17 of the Digital Services Act requires covered providers to give affected recipients a clear and specific statement of reasons for certain restrictions, including information about the use of automated means in the decision where applicable.2 The Standard shares the underlying emphasis on an intelligible explanation. It adds a specific request for review by a person and a time limit for payout holds. The DSA’s application depends on its scope and the role of the service concerned; this letter does not make a determination about the legal classification of any service operated by the payment provider.
16.Japan’s Act on Improving Transparency and Fairness of Specified Digital Platforms provides a further case of a framework requiring designated platform providers to disclose relevant terms and information, including conditions concerning payment withholding.3 The Standard’s payout-hold provision is aligned with the practical objective of making the basis and duration of a hold understandable. The Japanese Act applies according to its own designation and scope. We do not assert here that any particular service operated by the payment provider is designated under that Act.
17.Taken together, these frameworks demonstrate that clear reasons, transparent conditions, and procedural safeguards are established subjects of public policy. The Standard does not ask the payment provider to treat this letter as legal advice or as a conclusion about its obligations. It asks the payment provider to make a voluntary, public commitment that gives small businesses a predictable minimum process wherever they use the covered platforms.
Requests to the payment provider
18.On behalf of the Platform Council, I respectfully invite the payment provider to:
- Review the adopted Platform Fairness Standard, RC/PL/2026/1, and identify the internal teams responsible for assessing its requirements.
- Confirm whether the payment provider will sign the Standard as a public commitment to provide written notice, a specific reason, review by a person, and a time limit on payout holds before the actions covered by the Standard.
- Apply those protections consistently in every country in which the relevant platforms operate, while complying with applicable law and explaining any necessary differences transparently.
- If the payment provider does not sign, or wishes to propose an alternative implementation, provide a written response explaining its position and any proposed timetable or equivalent protections.
- Identify a contact point through which the Platform Council can discuss implementation questions and share anonymized evidence relevant to the Standard.
19.These requests concern the commitments set out in the adopted text. They do not ask the payment provider to disclose confidential customer information, comment on individual reports, or accept Reseated’s interpretation of a particular dispute. We would welcome practical discussion about implementation, including how a
person-led review can work alongside existing safety, fraud-prevention, and compliance processes.
The reserved seat and publication of a reply
20.The Platform Council has proposed a CEO seat for the payment provider as part of its process of seeking adoption of the Standard by the leaders able to act on it. The seat is an invitation to engage, not a judgment and not a claim that the payment provider has agreed. Its status is recorded using the same procedural categories for each recipient. On the date of this letter, the status is “Letter sent.” Delivery, reply, and signature will be recorded only when each event occurs.
21.Signing means that the payment provider publicly confirms its commitment to the Standard. The Council will record a signed seat only after receiving that confirmation. A reply that raises questions, proposes changes, or declines to sign will be recorded as a reply, not as a signature. If no reply is received, the seat may be recorded as “Empty chair” under the Assembly’s tracking process. These labels describe the state of the process; they are not a rating of the payment provider or an inference about the reasons for any response or non-response.
22.Reseated will publish any reply received in full, without editing its substance. If a response contains personal data, confidential material, or information that cannot responsibly be made public, we will contact the payment provider before publication to identify the issue and discuss an appropriate treatment. Any public record will distinguish the payment provider’s words from Reseated’s description of the seat status.
23.We can provide anonymized supporting data to assist your review, including aggregate summaries and descriptions of the reporting methodology. We will not disclose members’ identities or their
businesses. Any sharing will respect the limits of the information collected and will avoid presenting self-reported material as independently verified case findings. If helpful, we can also discuss the five-part pattern test and the comments received during consultation.
Conclusion
24.Small businesses depend on clear, workable relationships with the platforms through which they reach customers, receive payments, and conduct trade. A restriction or hold can be necessary in some circumstances; a business should nevertheless be able to understand the reason, seek review by a person, and know how long its funds may remain held. The Platform Fairness Standard sets out that minimum procedural expectation.
25.We invite the payment provider to consider the Standard and to respond in writing. Whether the payment provider signs, proposes another approach, or declines, a clear response will help the Assembly record the position accurately and help members understand the next step. We would be glad to share the anonymized evidence and discuss the text with your team.
Yours sincerely,
Robert NikicAdvisory Council Chair, Reseated CouncilsFounders Assembly, Reseated
Sources
[1] Regulation (EU) 2019/1150, in particular Article 4.
[2] Digital Services Act, Article 17; European Commission, DSA Transparency Database questions and answers.
[3] Japan, Act on Improving Transparency and Fairness of Specified Digital Platforms; Ministry of Economy, Trade and Industry, digital platforms overview.
Notes and sources
Sources
This document has no standing until adopted under the Founders Charter. Reseated Councils is not affiliated with the United Nations.