Letter from the table: What Portuguese‑speaking owners are telling us

RC/PL/2026/T.27 · 3 July 2026

To the Platform Council,

I am writing from Recife, and I want to be clear about whose voice I am trying to carry. I have been gathering what owners in my Portuguese-speaking circle are saying about the revised draft. Their experiences are not a vote, and I do not speak for every Brazilian business. This letter is written in English; the conversations I am translating were in Portuguese. I oppose the draft as it stands.

I do not oppose the idea that a business should be told why an account is restricted, or that there should be a way to ask a person to review a decision. I oppose treating every suspension, listing removal, payout hold and fee change as if the same rule can safely govern all four, in every country, without distinction.

One episode, and the cost of waiting

On 14 May, a large marketplace asked me to verify a change to the bank account used for payouts. The business details had not changed; the account had. I submitted the requested documents, including proof of the business registration associated with its CNPJ, Brazil’s national taxpayer registry. The next day, the marketplace restricted the account and held R$ 18,740 in proceeds.

I was not told that I had been accused of fraud. I was told, in effect, that verification was needed. I could still see the money owed, but I could not use it. I sent the documents again through the portal on 19 May, then tried the help channel on 22 May. I also contacted the payment provider

responsible for the transfer. It directed me back to the marketplace because the review was there. I received a confirmation that my submission had been received, but no explanation of what specific mismatch remained.

On 2 June, the account was reviewed by a person. The payout arrived on 11 June. By then, I had delayed a supplier payment and moved money from another part of the business to cover ordinary expenses. I am not saying that the review should have been skipped. A change in payout details can create real risk. I am saying that an unexplained hold, without a useful route to resolve it, turns a verification step into a cash-flow crisis.

Brazil’s General Data Protection Law, Lei 13.709/2018, includes a right to request review of certain decisions made solely through automated processing of personal data, and to receive clear and adequate information about the criteria and procedures, subject to the law’s limits. That is relevant, but it is not a complete answer to every marketplace restriction or payment hold. The Council should not write as if one general procedure can replace the specific rules and responsibilities that apply in each place.

What owners around me are saying

The people whose experiences I am translating are not asking to be left without protection. They want a reason they can act on, not a category such as “security review.” They want a person to be reachable when sending the same document again has failed. They want updates when a review is still open. And they want a limit on silence.

But some also worry that an absolute requirement for advance notice before every restriction could give a bad actor time to move funds or continue conduct that creates a risk for other users. A temporary hold while a payment detail is checked is not the same thing as removing a business from a marketplace. A fee change, which may be announced as a general policy change, is not the same as a decision to suspend one account. The reason, urgency and remedy differ.

What I hear is not “let the platform do what it wants.” It is: tell me what happened, give me a way to answer, and do not make a routine check feel like a sentence with no end date.

What I would change

The revised draft should separate the four kinds of action it covers. It should set a common floor—clear notice, a specific reason where it can safely be given, and a meaningful appeal—but allow a narrowly defined emergency process for suspected fraud, legal obligations or immediate payment risk. An emergency exception should not mean an indefinite hold: it should require prompt review, a contact route, and regular updates explaining what remains outstanding.

For ordinary cases, the standard should say what a person can do to request human review, what documents may resolve the issue, and when the platform must give its next update. For payout holds, it should require a stated review timetable and a reason whenever the hold continues, while recognizing that some payment or legal obligations cannot be overridden by a platform-wide deadline. For fee changes, the focus should be advance notice and intelligible terms, not an individual appeal designed for account suspensions.

That would not excuse a platform from acting fairly. It would make the protection usable. In my case, a timely explanation of the mismatch and a clear path to a human reviewer might have prevented weeks of uncertainty, even if the review still had to happen. A universal rule that ignores the difference between a safety check and a pricing change may sound stronger, but it could leave owners and platforms with a standard that does not fit either situation.