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

The clock is Turkish. 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, and the notice to the seller has to set out how to object (Article 12(3)). 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 that catches teams out is Article 10(3): awareness is deemed. 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); the statement of reasons carries no such carve-out. 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 objection is that this binds every other market to a Turkish deadline. It does. It is still cheaper than two queues, because the expensive part is not the timer, it is the reason taxonomy, and Article 24(5) publishes yours. Write reason codes tied to a legal ground, and let free text be an annex to the decision rather than the decision itself. 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)). That makes the gate an annual job with a due date, not a box ticked 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; the habit of holding evidence about your own service should not 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. None of this is a policy question. It is a rota, a taxonomy and a calendar entry, and the Friday inbox is where you find out whether you have all three.

Published 27 July 2026

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