Marketplace compliance ops: one notice queue, set to the tightest clock

The binding clock is the Turkish one. Under the Regulation on Electronic Commerce Intermediary Service Providers, published on 29 December 2022 and made under Law No. 6563, an intermediary that becomes aware content is unlawful must take it down without delay and within forty-eight hours, and tell the seller and the relevant public authority why (Article 10(2)). An intellectual property complaint runs on the same forty-eight hours, with the notice to the seller obliged to set out how to object (Article 12(3)), and where the objection is clearly made out on the documents filed the listing goes back up within twenty-four hours (Article 14(1)). The provision I keep watching teams discover late is Article 10(3), which deems awareness: a ministry notification or a notified court decision starts the clock whether or not anyone has opened the email.

The Digital Services Act sets the shape rather than the hour. Providers of hosting services owe a statement of reasons wherever they restrict a listing on the ground that it is illegal or breaches their terms (Article 17(1)). Providers of online platforms must run an internal complaint-handling system that stays open for at least six months after the decision (Article 20(1)), and the decision on that complaint has to be taken under the supervision of appropriately qualified staff, not solely by automated means (Article 20(6)). Those platform duties spare micro and small enterprises unless the platform is designated very large (Articles 19 and 33), while the statement of reasons carries no such carve-out, and that asymmetry is the one teams miss when they scope the work. And if you are an online platform rather than a bare hosting service, Article 24(5) sends those statements of reasons to the Commission’s public, machine-readable database, unless you are a micro or small enterprise that has not been designated very large.

So run one queue, and set it to the tightest clock in your footprint. The obvious objection is that this binds every other market to a Turkish deadline, and it does. It still costs less than running two, because the timer is the cheap half of the job and the reason taxonomy is the half that eats the year, and under Article 24(5) yours is the one on public display. Write reason codes tied to a legal ground, and let free text sit as an annex to the decision rather than stand in for it. Automate intake, deduplication, evidence assembly and the countdown. Do not automate the call.

The seller gate takes the same treatment. Article 30(2) of the DSA asks for best efforts to assess whether the trader’s information is reliable and complete; it binds platforms that let consumers conclude distance contracts with traders, and it spares micro and small enterprises unless the platform is designated very large (Article 29). Freshfields is right that the defensible artifact is a written record of what your best efforts were. Turkey draws a harder edge. The intermediary verifies the seller’s identifying information against the relevant institutions’ openly accessible electronic systems, or failing that against documents from the seller; it may not provide intermediary services to a seller it has not verified; and it re-checks that information in the first three months of every calendar year, allowing at most three business days to correct it (Article 6(3)). So the gate is a job with a date on it every year, and not a box someone ticked once at sign-up.

It is also where evidence comes from. When the Commission fined Temu 200 million euro on 28 May 2026, the finding was that its risk assessment rested on general information about the e-commerce sector rather than specific evidence about its own service. That systemic-risk duty binds platforms designated as very large, but the habit it points to, keeping evidence about your own service rather than about your sector, doesn’t need to wait for designation. Ranking parameters deserve the same discipline, and the questions to ask about them are their own subject; here only the artifact matters, a dated change record with a named owner. A rota, a taxonomy and a calendar entry: that is most of what this comes to, and the Friday inbox is where you find out whether you have all three.

Published 27 July 2026 · Last updated 5 September 2026 · 4 min read

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