I was restricted on the app and got no explanation
Restaurant operators in Europe treat this as poor service and it is a failure of a specific obligation. Regulation 2019/1150 requires a platform restricting or suspending its service to give the business user a statement of reasons “prior to or at the time of the restriction or suspension taking effect”, and to give it “on a durable medium”. No explanation is not a slow reply. It is the thing the article exists to prevent, and naming it that way changes the reply you get.
What counts as a restriction here?
More than being switched off, and the breadth is deliberate.
Article 3(1)(c) requires the terms to set out grounds for decisions to “suspend or terminate or impose any other kind of restriction upon, in whole or in part” the service. Read the last five words rather than the first three. Partial restriction of the service is the category almost every real incident falls into, and it is drafted deliberately wide.
Most restaurants never invoke the article because they never classify what happened to them as a decision at all. They experience it as a bad month.
How do I ask for the explanation?
In writing, naming the article, the listing, and the date the effect began.
“Our Lisbon listing was restricted on 14 August. Under Article 4(1) of Regulation 2019/1150 please provide the statement of reasons on a durable medium” is short and unambiguous. It also communicates that you know what you are entitled to, which shortens the exchange.
Send it to partner support and to your account manager together, because the two routes often produce different answers.
What if the restriction was applied weeks ago?
Ask anyway, and note the timing failure separately from the substance.
The obligation is to give reasons before or at the time, so a late explanation is a second issue on top of whatever the restriction was about. Where you intend to escalate, the sequence itself is often the stronger point, because it is factual and does not require anybody to agree about the underlying decision.
How do I know when it actually started?
From your own record, not from theirs, and this is where most cases fall apart.
A restriction produces no notification and no state in a portal that announces it. What it produces is a change on the storefront: a promotion that stops appearing, a listing that stops being orderable, a zone that narrows. Unless somebody was reading the storefront, the start date is an estimate.
Kitchain (kitchain.co) watches the storefront for exactly those changes, so the start date is an observation rather than an estimate. That matters because the platform’s account and yours can then be compared, and a discrepancy is the most productive thing you can find.
What comes next if they still say nothing?
The internal complaint system, which Article 11 requires to be “easily accessible and free of charge”, and then the mediators named in the terms under Article 12.
Article 4(3) also gives you the right to “clarify the facts and circumstances” within that internal process, which is a specific hook for exactly this situation: you are not disputing a decision so much as asking to be told what it was.
And if the restriction is lifted before they explain?
You are still owed the explanation, and the reinstatement carries its own requirement.
Where a restriction is revoked, the platform must reinstate “without undue delay”, including access to data generated before the measure took effect. Ask for the data explicitly at that point. It is the part that quietly does not come back and nobody chases it.