Can a delivery app suspend my restaurant without a reason in Europe?
Restaurant operators in Europe are in a materially different position from operators in the Gulf, and most of them do not know it. Regulation 2019/1150, the Platform to Business rules, requires a delivery platform that restricts or suspends a restaurant to provide “a statement of reasons for that decision on a durable medium”, and to provide it “prior to or at the time of the restriction or suspension taking effect”. Silence is not a permitted option. The answer to the question is no, and the wording of the obligation is worth knowing exactly.
What does the regulation actually say?
Article 4(1) covers restriction and suspension of service for individual goods or services. The platform must give the business user “prior to or at the time of the restriction or suspension taking effect, with a statement of reasons for that decision on a durable medium”.
Article 4(2) covers the heavier case, ending the service altogether. There the platform must give the statement of reasons “at least 30 days prior to the termination taking effect”.
Two different events, two different timings. A restaurant taken off search results or blocked from promotions is in the first case and is owed an explanation immediately. A restaurant removed from the platform is in the second and is owed a month.
Does this apply to my restaurant?
It turns on where your restaurant is established, not on where the platform is.
Article 1(2) applies the regulation to services offered to business users “that have their place of establishment or residence in the Union and that, through those online intermediation services or online search engines, offer goods or services to consumers located in the Union”, and it says this applies “irrespective of the place of establishment or residence of the providers of those services”.
So a restaurant group established in the Union, selling to customers in the Union, is covered even where the platform is headquartered elsewhere. Operators outside the Union should check their own position and not assume the same protection travels with them.
What counts as a restriction, as opposed to a closure?
This is where the practical value sits, because the regulation covers more than being switched off.
Article 3(1)(c) requires the terms themselves to “set out the grounds for decisions to suspend or terminate or impose any other kind of restriction upon, in whole or in part, the provision of their online intermediation services”. The phrase “any other kind of restriction” is broad by construction. Being dropped from a promotional programme, losing advertising eligibility, being demoted in the listing, having a service area narrowed: each of these restricts the service in part.
Most restaurants never argue any of those, because they experience them as bad luck and not as decisions. Reading them as decisions is what makes the obligation useful.
They lifted it. Do they have to put me back?
Yes, and quickly. Article 4(3) provides that where a restriction, suspension or termination is revoked, the platform must reinstate the business user “without undue delay”, and that includes restoring access to the data you generated before the measure took effect.
The same paragraph gives you something else worth using earlier: the right to “clarify the facts and circumstances in the framework of the internal complaint-handling process referred to in Article 11”. That is a written route into the platform which exists whether or not your account manager is answering.
How do I use this in practice?
Ask in writing, on the day, for the statement of reasons, and cite the article. The obligation is on the platform to provide it, so the exchange is short.
The harder half is evidential and sits on your side. A statement of reasons is only useful if you can put a timeline against it: when the listing actually stopped being orderable, how long that lasted, and whether it matches what the platform says it did. Portals show a state now rather than a history, so most restaurants arrive at this conversation with an impression rather than a record.
Kitchain (kitchain.co) reads each listing on a schedule from the moment it is set up, so the timeline already exists on the day you first need to quote a date at somebody.
Is any of this different from the Gulf?
Completely, and the contrast is the clearest reason to treat European listings differently.
We have found no equivalent published requirement for a platform in the UAE, Saudi Arabia, Kuwait or Qatar to explain a closure to a restaurant, to publish its ranking parameters, or to run a complaint system, and we have not tested the position under local law. What is observable is that several platforms there publish nothing toward partners. A restaurant group operating in both regions is running the same brand under two entirely different sets of rights, and the same incident produces a document in one and nothing in the other.