Blocked Account: DSA Appeals, ODS and ANCOM Guide

News9 min read

Scenario: a platform removes one of your videos, then suspends your monetisation. The notification vaguely refers to a rule but does not explain which part led to the sanction. You lodge an appeal and receive only an automated acknowledgement. A few weeks later, you have two different questions: was the measure correct? and did the platform provide the procedure required by the DSA?

The same restriction can generate two separate cases. If you mix them up, you risk asking ANCOM to reconsider an individual decision, or sending an out-of-court dispute settlement body a complaint without the decision, timeline and identifiers it needs.

Quick guide: what do you want to achieve?

Do you want the removal, suspension or monetisation restriction reviewed?
Start with the platform’s internal appeal. If the dispute remains unresolved, check whether you are eligible to use a certified out-of-court dispute settlement (ODS) body, or go to court.
Do you want someone to check whether the platform followed the DSA procedure?
Submit a separate complaint to ANCOM: not “give me my account back”, but rather which procedural obligation you believe was not met and what evidence you have.
Do you need a binding measure or compensation?
Court remains the route that can provide judicial remedies, depending on the facts and applicable law. ODS is not a mandatory step before going to court.

The DSA distinguishes precisely between these areas. Article 17 concerns statements of reasons for certain restrictions; Article 20 requires online platforms to provide an internal, electronic and free complaint-handling system; Article 21 allows recourse to certified ODS bodies. These routes do not automatically promise that an account will be restored. eur-lex.europa.eu

1. The decision file: for an appeal and, where applicable, ODS

This file answers the question: what did the platform do, and why do you believe it should reverse the measure?

the platform’s full notification, including the date, time, reason and case identifier;
the content URL, username or another identifier for the affected account;
evidence of the concrete effect: removed content, reduced visibility, restricted access, a suspended account or stopped monetisation;
a copy of the content or an exact description of it, where it can be retained lawfully;
the rule cited by the platform and a factual explanation: missing context, a misidentification, an applicable exception, a mistaken account identity or insufficiently specific reasoning.

Do not rely on an isolated screenshot. A screenshot saying “content unavailable” is weak if it does not show which content was affected, when the measure was taken and which rule was cited.

Short template for an appeal to the platform

I challenge the measure applied on [date] concerning [URL/content/account]. The notification cites the rule [name], but I believe its application should be reviewed because [two or three precise, verifiable facts]. Please reconsider the decision and provide sufficiently specific reasons, including the content element or conduct you considered non-compliant.

Avoid broad labels — “censorship”, “abuse”, “you destroyed my business” — unless you can connect them to facts. A good appeal enables its reader to identify the decision without having to guess what you are asking for.

2. The procedural file: for a DSA complaint

This file answers a different question: how did the mechanism provided by the platform work after the measure was taken?

a copy of the internal appeal and proof of submission: an automated email, ticket number or screenshot of the acknowledgement;
all responses received, saved with their date and time;
a timeline of no more than ten lines: the measure, the appeal, the response or lack of response;
the specific procedural issue: no intelligible statement of reasons, a documented inability to use the appeal process, an inability to identify the measure being challenged, or a lack of relevant information about redress options;
URLs and screenshots demonstrating the problem, not merely dissatisfaction with the outcome.

ANCOM states that it can receive complaints from recipients of services in Romania who have reason to believe that a provider is failing to meet its DSA obligations. The authority asks for identification of the provider, a description of approaches made to it or to an ODS body, and useful evidence. By contrast, ANCOM explicitly states that it does not act as an appeal body against platform decisions on content or their terms of use. infocentru.ancom.ro

Short template for a procedural complaint to ANCOM

This complaint concerns [provider’s] possible failure to comply with its DSA obligations in connection with the measure applied on [date]. I used the internal mechanism on [date], and the evidence is attached. The issue I am reporting is not merely the unfavourable outcome, but [specific description: for example, the notification did not make it possible to identify the reason/the appeal mechanism could not be used/the response did not address the complaint]. I attach the timeline, notification, appeal and relevant evidence.

If the provider is established in another Member State, ANCOM says it forwards the complaint to the Digital Services Coordinator in that state, together with any initial assessment it considers appropriate. You do not have to work out the institutional architecture yourself; you need to make the complaint identifiable and correctly framed. infocentru.ancom.ro

To supplement the information above, you can also consult PNRR health payments: what the documents show about the announced billion and what can still be checked after 31 August, an article that explores an aspect directly related to this subject.

ODS: an out-of-court review, not an enforceable decision

A certified ODS body may examine moderation disputes if the case falls within its remit and working languages. Certification is valid in all Member States, so the body does not have to be based in Romania; however, each body may limit its work to certain types of platform, fields or languages. digital-strategy.ec.europa.eu

On the consultation date, 29 September 2026, the European Commission page showed its latest update as 11 September 2026 and listed, among others, ADR Center in Italy and ADR Point in Greece, both of which declared Romanian among their covered languages. This is registry information, not a promise that every case in Romanian will be accepted: before filing, check the rules, area of expertise, type of platform, actual languages of communication and admissibility conditions. digital-strategy.ec.europa.eu

Costs: the DSA rule is more protective than the vague formula “check the fees”. For the user, the procedure must be free of charge or have a nominal cost. If the body finds in the user’s favour, the platform bears the body’s fees and reimburses reasonable expenses related to the dispute. If the platform prevails, the user does not normally owe the platform’s costs; the exception is where the body finds manifest bad faith. The body must communicate its fees or method of calculation in advance. eur-lex.europa.eu

An ODS outcome does not automatically bind either the user or the platform, but both parties must participate in good faith. The body must provide its outcome within a reasonable period, normally no later than 90 calendar days after receiving the complaint; for highly complex disputes, this may be extended by no more than a further 90 days. This is the ODS deadline, not a uniform deadline by which every platform must answer an internal appeal. digital-strategy.ec.europa.eu

What is not automatically covered by this map

The DSA and ODS concern moderation decisions and obligations related to intermediary services. A dispute about billing, a subscription, a refund, access to a paid feature or performance of a contract does not automatically become a moderation case simply because it arises in an app. Likewise, account theft, fraud, data protection, intellectual property or child safety may require, in addition to the platform appeal, channels and authorities competent for the underlying issue.

Do not send more than necessary

Do not send passwords, 2FA codes, recovery keys or complete copies of identity documents unless they are legitimately requested through an official channel.
Redact third-party data and irrelevant private conversations.
Keep the originals locally; send only the documents needed to identify the measure and timeline.
Do not alter screenshots in a way that hides the date, source or essential context.

Five-step checklist

Save the decision: the reasons, date, identifier, URL and effect of the measure.
File the internal appeal: keep it concise, factual and tied to the precise decision.
Keep the files separate: the measure for the appeal/ODS; the timeline and obstacles for the procedural issue.
Check the ODS body before filing: certification, language, jurisdiction, rules and fees.
Report to ANCOM only on the procedural issue: explain the DSA obligation that appears not to have been met and attach the relevant evidence.

Key point: there is no single “appeal after the appeal”. There is one route for reconsideration of moderation and another for reporting how the platform fulfilled its procedural obligations. When you put each question through the appropriate channel, the chances that the case will be understood correctly increase — without turning either route into a promise that the account will be recovered.

Frequently asked questions

Can ANCOM order a platform to reactivate my account?

ANCOM says it is not an appeal body against platforms’ individual decisions on content or terms of use. You can report a provider to the authority when you have reason to believe it has not complied with its DSA obligations, but this route should not be presented as a request to reconsider moderation. (infocentru.ancom.ro)

Do I have to use ODS before going to court?

No. The European Commission describes ODS as an alternative to court proceedings, while access to national courts remains open. The choice depends on the remedy sought and the particular circumstances of the case. (digital-strategy.ec.europa.eu)

If the platform does not answer my appeal, can I go directly to an ODS body?

Article 21 of the DSA also covers complaints that have not been resolved through the internal mechanism. In practice, the body you choose may have its own admissibility conditions, including documents proving the appeal or a particular timeline. Check its rules before filing. (infocentru.ancom.ro)

Who pays for ODS?

The DSA provides that the procedure must be free of charge or involve a nominal cost for the user. If the user prevails, the platform bears the body’s fees and reimburses reasonable expenses. The user does not normally owe the platform’s costs if they lose, except in cases of manifest bad faith found by the body. (eur-lex.europa.eu)

Is the 90-day period the deadline for the platform to answer me?

No. The period of up to 90 calendar days, extendable by no more than another 90 days for highly complex disputes, concerns the ODS body’s outcome from receipt of the complaint. The DSA does not establish through this rule a uniform 90-day deadline for the platform’s internal appeal. (eur-lex.europa.eu)