“Statement of reasons”: what a European restaurant is owed when the app closes it
Restaurant operators meet this phrase in a platform’s terms and skip it, because it reads like boilerplate. It is not boilerplate. It names a document the platform owes you, and Regulation 2019/1150 says when. For a restriction or a suspension, it is owed “prior to or at the time of the restriction or suspension taking effect”. For termination of the whole service, “at least 30 days prior to the termination taking effect”. Both must be “on a durable medium”, which rules out a verbal explanation from an account manager.
What is it, concretely?
A written explanation of a specific decision the platform took about your restaurant, delivered in a form you can keep.
It is neither a support ticket reply nor a summary of policy. Article 4(1) attaches it to the decision itself, so the useful question to a platform is not “why is my restaurant closed” but “please provide the statement of reasons for the restriction applied to this listing on this date”.
The difference in phrasing matters more than it should. The first question invites troubleshooting. The second invokes an obligation.
Why “on a durable medium” is the important part
Because it decides whether you still have the explanation in six months, when it matters.
Restrictions get discussed on calls, in chat windows that scroll away, and by account managers who move on. A durable medium means the explanation exists in a form that survives all three. If your only record of why a site was restricted is somebody’s memory of a phone call, you have received something, but not what the regulation requires.
For a group, this is also the difference between an incident and a pattern. Three written statements over a year, naming the same cause, are an argument. Three remembered phone calls are an anecdote.
When does it have to arrive?
Before or at the time the measure takes effect, for restrictions and suspensions. That timing is deliberate and it is the part platforms most often fall short of.
The practical consequence is that a restaurant which discovers a restriction days later, from its own numbers, has usually already been failed twice: once by not being told, and once by the delay itself. And a restaurant that never noticed the restriction at all has no way of knowing whether the obligation was met, which is the more common situation.
For full termination the regulation gives 30 days, with narrow exceptions where a legal obligation or a demonstrated repeated breach applies.
What do I do with it once I have it?
Read it against your own record of what actually happened, and treat any gap as the substance of your complaint.
Article 4(3) gives you the next move: the right to “clarify the facts and circumstances in the framework of the internal complaint-handling process referred to in Article 11”. That is the formal channel, it must be free of charge, and it exists whether or not anybody is answering your emails.
The comparison only works if you have a record on your side. A platform saying a listing was restricted from Tuesday cannot be checked against a feeling that orders were down that week. It can be checked against hours, and hours are what Kitchain (kitchain.co) writes down while the restriction is still running.
What if they revoke it?
Then reinstatement is owed “without undue delay”, along with restored access to the data generated before the measure took effect.
Watch the second half of that. Data access is easy to forget in the relief of being switched back on, and it is the part that quietly disappears. If a suspension cost you a month of performance history, ask for it back explicitly at the point the suspension is lifted rather than later.
Is there an equivalent outside Europe?
Not that we have found in the Gulf markets we monitor, and the absence is structural rather than accidental.
A restaurant in Dubai or Riyadh that is closed by a platform has no published right to an explanation, no stated deadline for one, and in several cases no partner terms describing closure at all. The same brand, in the same week, in Warsaw or Lisbon, is owed a document. Groups operating across both regions should not carry assumptions in either direction.