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RC/PL/2026/24

Letter to National Competition and Consumer Authorities Transmitting the Platform Fairness Standard

10 September 2026 · Letter · From Robert Nikic (Advisory Council Chair, Reseated Councils; based in the United States) · To competition and consumer protection authorities Circulated

Document info

Document info

Symbol
RC/PL/2026/24
Date
10 September 2026
Kind
Letter
Status
Circulated
Council
Platform
Agenda item
PL-001
From
Robert Nikic (Advisory Council Chair, Reseated Councils; based in the United States)
To
competition and consumer protection authorities
Sitting
General

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8 pages · US Letter

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Platform Council

RC/PL/2026/24Circulated

Letter to National Competition and Consumer Authorities Transmitting the Platform Fairness Standard

To: National competition and consumer protection authorities

Dear colleagues,

We write on behalf of the Platform Council of the Founders Assembly to transmit the Platform Fairness Standard, adopted by the Assembly on 13 August 2026 as RC/PL/RES/2026/1. We ask your offices to consider the standard as a practical description of procedural safeguards for business users who depend on digital platforms, and to tell us how the issues it addresses intersect with the laws and responsibilities in your jurisdiction.

We recognize that your offices have distinct mandates, statutory powers and procedures. This letter does not presume that a particular authority has jurisdiction over a particular platform or practice. It does not ask you to reach a conclusion about any named company. It offers a documented pattern of reports, a narrowly framed standard and a set of requests for consideration within your own mandate.

Who we are and what we are authorized to do

Reseated is a global assembly of small-business owners, organized in seven councils. The Founders Assembly was launched on 10 February 2026. Its Founders Charter, RC/A/2026/1, establishes a member-led process for identifying recurring business problems and developing proposed practices in response. Reseated is a nonprofit.

The Platform Council brings together members who report relying on digital platforms to reach customers, list products or services, receive payments, or otherwise operate their businesses. The Council does not represent a single company or platform. Its work describes reported practices across platform relationships. Members remain anonymous unless they choose to occupy a public seat, and member accounts do not identify the member’s own business.

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Our process is intended to distinguish recurring patterns from isolated accounts. Reports are assessed through a five-part pattern test: Volume, Frequency, Consistency, Spread and Corroboration. When a problem meets that test, the Council may draft a proposed fix, invite public consultation and submit a recommendation to an Assembly ballot. After adoption, the Assembly transmits the recommendation to relevant decision-makers and tracks whether a letter was sent, delivered, answered or signed. The Platform Fairness Standard followed this process. The Assembly adopted it by ballot on 13 August 2026, with 86.4 per cent voting yes and 58 per cent turnout.

The evidence in the Council’s records as of 10 September 2026

As of 10 September 2026, Reseated had 1,499 seated members in 49 countries and had received 4,552 reports from 50 countries. Of those reports, 1,865 were filed with the Platform Council. The Council had 445 members in 48 countries. Its reported median amount at stake was approximately US$4,099.

The Platform Council’s reports described two principal situations: funds held, reported in 819 cases; and accounts suspended, reported in 1,046 cases. These categories describe the situation reported and should not be treated as a finding that a platform acted unlawfully or that every case had the same cause or outcome.

The reports came from businesses of varied sizes. Among Platform Council members, 36 per cent described their team as just themselves, 43 per cent as two to nine people, 17 per cent as 10 to 49 people, and 4 per cent as 50 to 249 people. The Council received 143 reports in the 30 days preceding this letter.

Reports to the Platform Council came from 50 countries. The countries with the highest reported counts were the United States, 219; Germany, 113; Brazil, 106; Mexico, 100; the Philippines, 99; Spain, 96; the United Kingdom, 87; and France, 87. These figures count reports, not unique businesses, and are not population-adjusted. They should not be interpreted as a ranking of national incidence or as a measure of the conduct of any particular platform in a country.

The Council’s records do not include a verified sector-by-sector count. We therefore make no claim about the relative prevalence of the reported practices in particular industries. The figures are member reports gathered through the Council’s process; they are not a survey of all small businesses, an adjudication

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of individual disputes or a substitute for evidence gathered under your office’s procedures.

The broader council totals provide context for the assembly’s work. Of the 4,552 reports received across Reseated, 1,865 were assigned to Platform, 1,202 to Cashflow, 518 to Fair Play, 369 to Trade, 240 to Red Tape, 223 to Resilience and 135 to Team. These are the totals recorded as of 10 September 2026. The Platform Council’s interim review and certification of its pattern test are recorded in RC/PL/2026/N.1 and RC/PL/2026/N.2.

What the Standard proposes

The Platform Fairness Standard asks that, before an account is suspended, a listing is removed, a payout is held or a fee is changed, a platform provide the affected business user with written notice, a specific reason, review by a person and, for a payout hold, a time limit. It further asks that these protections apply in every country in which the platform operates.

The standard is a proposed baseline of fair process, not a claim that every decision should be reversed or that platforms should be prevented from addressing fraud, safety, legal compliance or other legitimate risks. It does not prescribe a single investigation method or require disclosure of information whose release would create a concrete security or legal risk. Its central concern is whether a business user can understand the action taken, identify what is required to respond, seek meaningful review and know how long funds may remain unavailable.

In the Assembly’s view, these safeguards are practical. A specific reason gives a business user a chance to correct an error or supply missing information. Human review offers a route to examine context that an automated or standard process may not resolve. A time limit on a payout hold can help a business plan around money it is owed, while allowing a platform to investigate a genuine concern. Applying the same procedural protections across operating countries avoids making a business’s ability to obtain an explanation depend solely on where it is located.

The law differs by jurisdiction. We do not suggest that the following cases govern every recipient or every platform relationship. They illustrate that procedural transparency for business users is already addressed in some legal and policy frameworks.

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In the European Union, the Platform-to-Business Regulation provides for a statement of reasons when a provider restricts or suspends a business user, and requires at least 30 days’ notice before terminating the whole service, subject to the Regulation’s terms and exceptions.1 The Digital Services Act provides for statements of reasons for specified decisions affecting recipients of intermediary services. Its Article 24(5) provides for the Commission’s Digital Services Act Transparency Database; the database was launched in September 2023.2 These provisions are relevant cases of structured explanation and transparency, but their scope and application depend on the relevant law and facts.

In Japan, the Act on Improving Transparency and Fairness of Specified Digital Platforms addresses designated digital platforms, including designated online malls. The Japanese framework requires disclosure of conditions relating to matters including the withholding of payments; the designation and applicable obligations are matters for the competent authorities under the Act.3 We cite this as a jurisdiction-specific case, not as a rule applicable outside Japan.

These cases do not resolve the questions before national authorities elsewhere. We invite each recipient to assess the Platform Fairness Standard against its own competition, consumer-protection, digital-market and business-user frameworks, where relevant. We also recognize that some authorities may have a role in monitoring transparency, some in investigating conduct, and others in advising government or directing affected parties to another competent body.

Requests to national authorities

We respectfully ask your office to consider the following steps, as appropriate to its mandate and resources:

  1. Review the transmitted standard. Consider whether written notice, specific reasons, accessible review by a person and a time limit for payout holds are useful procedural benchmarks in your work concerning platform-dependent businesses. The standard is enclosed by reference as RC/PL/RES/2026/1.

  1. Identify the relevant local framework. If these issues fall within your remit, please indicate which laws, guidance, complaint routes or other mechanisms may apply to account suspensions, listing removals, payout holds or fee changes affecting business users. If they do not fall within your remit, a referral to the appropriate public office would help members direct concerns responsibly.

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  1. Consider the practical consequences of process gaps. When reviewing complaints or policy questions, consider whether the affected business received notice, a reason it could act on, an opportunity for human review and a clear indication of the duration or review point for any payout hold. We ask this as a procedural inquiry, not as a presumption that any specific report establishes a violation.

  1. Encourage clear, accessible complaint pathways. Where appropriate, publish or clarify how a small business can raise a concern about a platform decision, what information is useful to provide, what response process is available and whether an alternative public authority is responsible for a related issue.

  1. Consider consistency across borders. Where platforms operate across multiple countries, consider whether differences in notice, review and payout processes create avoidable uncertainty for business users. We do not ask authorities to displace local law; we ask that cross-border variation be examined where it is relevant to your work.

  1. Engage with the evidence cautiously and constructively. If the reported patterns are relevant to an inquiry, consultation or policy review, we ask that they be treated as a basis for questions and further evidence-gathering, not as proof of individual liability or a complete measure of prevalence.

  1. Tell us how to provide useful information. Please let us know whether your office would welcome anonymized, aggregated data; what safeguards or format it requires; and which topics would make such information most useful to your work.

Offer of anonymized data

The Platform Council is prepared to discuss providing anonymized and aggregated information within appropriate safeguards. Any such discussion would begin with your office’s stated purpose, data requirements and confidentiality procedures. We would not provide member names or the names of members’ businesses as part of an ordinary aggregate data offer. We would also avoid presenting small groups or combinations of characteristics in a way that could reasonably identify a member.

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The current figures in this letter are intentionally limited. If your office needs information at a more detailed level—for instance, a clearer distinction between reported event types, time periods or outcomes—we would first assess whether the relevant data can be prepared consistently and safely. We welcome a conversation about a suitable protocol before any transfer is considered.

Closing

Small businesses should be able to understand a consequential platform decision and know how to seek review. That is the practical point behind the Platform Fairness Standard. We hope the standard and the evidence summarized here can support careful discussion between public authorities and the businesses whose operations increasingly depend on digital services.

Thank you for considering this letter. We would welcome a written acknowledgement or a referral to the appropriate office, and we will record any response accurately. We do not presume a response or a position from any recipient.

Yours sincerely,

Robert NikicAdvisory Council Chair, Reseated Councils

For the Platform Council:Rapporteur, Platform Council

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Annex: sources and records

  1. Regulation (EU) 2019/1150, including Article 4 on statements of reasons and notice for termination of the whole service.1

  2. European Commission, Digital Services Act Transparency Database: questions and answers, including information on the database provided for under Article 24(5) and its operation.2

  3. Japan Act on Improving Transparency and Fairness of Specified Digital Platforms, English translation; and the Ministry of Economy, Trade and Industry’s information on digital platforms and the Act.3

Reseated records

  • RC/PL/2026/N.1, Interim pattern review: volume and frequency of suspensions and payout holds, 23 April 2026.

  • RC/PL/2026/N.2, Certification of the pattern test for PL-001, 12 May 2026.

  • RC/PL/2026/RES/2026/1, Resolution adopted by the Founders Assembly: the Platform Fairness Standard, 13 August 2026.

  • Platform Council membership and report aggregates, recorded as of 10 September 2026.

Notes and sources

  1. Regulation (EU) 2019/1150: https://eur-lex.europa.eu/eli/reg/2019/1150/oj/eng ↩
  2. European Commission, Digital Services Act Transparency Database — questions and answers: https://digital-strategy.ec.europa.eu/en/faqs/dsa-transparency-database-questions-and-answers ↩
  3. Japan Act on Improving Transparency and Fairness of Specified Digital Platforms: https://www.japaneselawtranslation.go.jp/en/laws/view/4533/en ; Ministry of Economy, Trade and Industry, Digital Platforms: https://www.meti.go.jp/english/policy/mono_info_service/information_economy/digital_platforms/index.html ↩
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This document has no standing until adopted under the Founders Charter. Reseated Councils is not affiliated with the United Nations.