A safeguard should not turn every interruption into the same case

To the Platform Council,

I oppose adopting the revised Platform Fairness Standard in its present form. I say this as someone who has needed the protections at its centre. A business should not have to guess why its account or money has been restricted. But a standard that treats different kinds of interruption as if they were one event may promise a certainty that neither the law nor a responsible platform can always provide.

What happened to me

On 18 March 2026, I received notice that a payout of €3,840 was being held while a review was conducted. The account itself remained accessible, but I could not transfer the money. On 20 March, one of my listings became unavailable. The notice did not tell me whether the two actions were connected. It referred to a review of account information, without identifying what information needed correction or giving me a date by which the review would finish.

I wrote through the platform’s appeal channel on 21 March. I asked for the reason for the hold, whether the listing action was part of the same review, and what documents I could provide. I also checked the contract terms and the European rules for business users. On 25 March I sent a formal request through the platform’s published legal contact, asking for a specific explanation and a timetable. I kept copies of the notices and of every submission. I did not know whether I was waiting for a routine check, responding to a concern about my account, or simply in a queue.

On 2 April the payout was released. The money mattered: while it was unavailable, I had to postpone a €1,260 payment due to a supplier and use funds set aside for other operating costs. I am glad the hold ended. But its ending did not tell me what had triggered it, whether the listing action had been separately reviewed, or what I should do differently if it happened again. I do not claim that the platform acted unlawfully. I am describing the practical gap between receiving a notice and being able to understand or respond to it.

What the law already gives us—and what it does not

In Italy, the EU Platform-to-Business Regulation applies directly. Article 4 requires a provider restricting or suspending a business user to give a statement of reasons. The Regulation also provides for advance notice in the case of termination of the entire service, subject to exceptions. That is not the same as a universal 30-day notice period for every temporary payout hold or listing restriction.¹

That distinction matters to my case. A statement of reasons could have helped me understand the listing action, but my immediate difficulty was that the notice did not tell me what information was needed or when the money would be available. A reason is not always a route to resolution; a deadline is not always possible where a genuine legal or security concern must first be checked. My experience does not show that every hold is justified. It shows that the word “hold” can cover situations with different causes and different lawful responses.

I tried the internal appeal first because it was the route available to me. I considered seeking legal advice, but the amount and duration did not make a formal dispute an easy first step for a small firm. A right that takes substantial time and expense to exercise can be real in law and still be difficult to use in practice. The Standard is right to ask what happens between the notice and a meaningful review.

Why I oppose this draft

The revised draft offers four protections before an account suspension, listing removal, payout hold or fee change: written notice, a specific reason, review by a person, and a time limit on payout holds, with the same protections in every country where a platform operates. I support clear notice and a way to obtain human review. I also support requiring platforms to communicate the status of a payout hold rather than leaving a business without a usable timetable.

My objection is to adopting all these measures as one uniform rule without sufficiently distinguishing their application. A temporary hold may follow an ordinary verification request; another may be required by law or connected to suspected fraud, security, or a dispute over funds. A fixed time limit cannot by itself resolve those differences. If a platform must release money simply because a general clock has run out, the rule could conflict with a legal restriction. If the clock can be extended whenever a platform says a review is continuing, the limit risks becoming only a formality.

The promise of “the same protections in every country” also needs careful drafting. A consistent minimum standard is valuable. But the steps a platform may lawfully take, and the information it may disclose, can depend on local obligations. The draft should say what must remain consistent—notice where lawful, a useful explanation, a route to human review, and regular updates—while making clear how a platform must explain a legal exception and when it must revisit that exception.

I would ask the Council to return the draft for a narrower and more workable version: separate rules for account access, listings, payouts and fee changes; require a specific explanation unless disclosure is legally prohibited; require a named next step or review date; and require periodic status updates when a hold cannot lawfully be lifted by a stated date. For legally compelled holds, the business should be told, as far as permitted, that a legal restriction prevents ordinary review or disclosure. Where there is no such restriction, a human review should be available within a defined period.

These changes would not excuse vague notices. They would make the protections more credible by matching them to the problem they are meant to solve. My own payout was released, but I was left without a clear account of why it had been held. I want the Council to address that failure. I cannot support a standard that risks replacing uncertainty with an absolute promise that may not be kept.

Notes and sources

Sources

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