In short. Covered online platforms must offer free electronic complaints for at least six months from notification and supervise complaint decisions with qualified staff.
Definition: Article 20 of the Digital Services Act (DSA) requires covered online platforms to offer free electronic complaints against specified content moderation decisions, including decisions on notices. Access lasts at least six months from notification, and complaint decisions require supervision by appropriately qualified staff.
Key facts
- DSA Article 20(1) and (2) give service recipients, including notice submitters, at least six months from notification to lodge a complaint.
- The European Commission's illegal-content guidance identifies the decision message, support inbox, account settings and help center as places where platforms explain access to their complaint system.
- The Commission's user-rights guidance identifies dispute settlement under Article 21 as another remedy, including when internal review leaves the dispute unresolved.
Which services must provide the system?
An online platform is a hosting service that stores information at a user's request and disseminates it to the public. DSA Article 3(i) excludes certain minor, ancillary features that depend on another service. Article 2(1) covers intermediary services offered to recipients established or located in the EU, regardless of the provider's location. Article 93(2) sets general application from 17 February 2024.
Article 19 exempts providers qualifying as micro or small enterprises under Recommendation 2003/361/EC from Article 20. The exemption generally continues for 12 months after that status is lost. Platforms designated as very large online platforms under Article 33 remain subject to these duties regardless of enterprise size.
Which decisions can users contest?
Article 20(1) covers decisions taken following a notice and decisions based on alleged illegality or incompatibility with the platform's terms and conditions. The listed measures include removing information, disabling access and restricting visibility. They also include suspension or termination of all or part of the service, suspension or termination of an account, and suspension, termination or other restrictions on monetising the recipient's information.
The provision covers decisions whether or not to take those measures. Individuals and entities that submitted a notice can also complain about the platform's decision on it, including a decision to leave reported content available.
How must complaints be submitted and handled?
Article 20(1) to (3) requires an effective electronic system, free of charge, that is easy to access and user-friendly. It must facilitate sufficiently precise and adequately substantiated complaints. The minimum six-month window starts on the day the recipient is informed of the decision under Article 16(5) or Article 17.
The Commission's guidance, updated in August 2026, explains access to free review through the platform's own complaints system. It covers account restrictions, content removals and rejected illegal-content reports.
What safeguards apply to the review?
Article 20(4) to (6) requires timely, non-discriminatory, diligent and non-arbitrary handling. The platform must reverse its decision without undue delay when the complaint provides sufficient grounds showing that refusal to act on a notice is unfounded, that the information is lawful and compatible with its terms, or that the complainant's conduct does not warrant the measure.
The platform must communicate a reasoned decision without undue delay and explain the possibility of out-of-court dispute settlement under Article 21 and other available redress. Appropriately qualified staff must supervise complaint decisions, which cannot rest solely on automated means.
Related terms
- Which DSA platform duties have a microenterprise exemption?
- What explanation must a host give when removing a user's content?
- What must an illegal-content notice mechanism contain under the DSA?
- How does DSA Article 21 apply to platform moderation disputes?
FAQ
Can I complain if the platform leaves reported content online?
Yes. Article 20(1) includes notice submitters and decisions whether or not to remove information or restrict access or visibility.
Must the platform answer within six months?
Six months is the minimum period for lodging your complaint, measured from notification. Article 20 sets no fixed number of days for a reply; it requires timely handling and communication without undue delay.
Can a platform decide my complaint entirely automatically?
Article 20(6) requires supervision by appropriately qualified staff and prohibits decisions based solely on automated means.
Sources
- EUR-Lex, "Regulation (EU) 2022/2065 (Digital Services Act)", 19 October 2022
- European Commission, "Tackling illegal content online with the Digital Services Act", 17 August 2026
- European Commission, "User rights under the Digital Services Act", 17 July 2026
Check how a page reads to answer engines. Open the GEO score analyzer