EU DSA Statement of Reasons Template

This document is the operating template used by Tanqory Inc. ("Tanqory", "we", "us") to issue a "statement of reasons" within the meaning of Article 17 of Regulation (EU) 2022/2065 (the Digital Services Act, "DSA") and to submit that statement to the publicly accessible database operated by the European Commission under Article 24(5) DSA (the "DSA Transparency Database"). It is read together with the EU Digital Services Act Regional Annex (annex/regions/digital-services-act-eu.md), the Acceptable Use Policy, the Terms of Service, and the Privacy Policy. The template is used by Tanqory operational teams ("Trust & Safety") and by automated tooling that prepares statements of reasons in machine-readable form.

Authoritative sources:

• Regulation (EU) 2022/2065 (Digital Services Act): https://eur-lex.europa.eu/eli/reg/2022/2065/oj
• DSA Transparency Database: https://transparency.dsa.ec.europa.eu/
• European Commission DSA portal: https://digital-strategy.ec.europa.eu/en/policies/digital-services-act-package

1) Purpose and trigger conditions

A statement of reasons is issued, in a clear and specific manner, to the affected recipient of the service whenever Tanqory imposes one of the following restrictions on the ground that the information provided by the recipient is illegal content or incompatible with the terms and conditions of Tanqory (Article 17(1) DSA):

• (a) any restriction of the visibility of specific items of information provided by the recipient of the service, including removal of content, disabling access to content, or demoting content;
• (b) suspension, termination, or other restriction of monetary payments to the recipient (where applicable to creator or affiliate programmes);
• (c) suspension or termination of the provision of the service, in whole or in part, to the recipient; or
• (d) suspension or termination of the recipient's account.

A statement of reasons is also issued where Tanqory acts on its own initiative on the basis of Article 14 (terms and conditions) or in response to an order from a Member State authority under Article 9 (orders to act against illegal content) or to a notice received under Article 16 (notice and action mechanism). A statement of reasons is not required where the information concerned is deceptive high-volume commercial content (Article 17(2)).

2) Required content of the statement of reasons (Article 17(3))

Every statement of reasons issued by Tanqory contains at minimum the following information, structured to enable automated parsing for the DSA Transparency Database:

• (a) Decision type. Indication of whether the decision entails the removal of, the disabling of access to, the demotion of, or the restriction of the visibility of the information, or the suspension or termination of monetary payments related to that information, or imposes other measures referred to in Article 17(1), and, where relevant, the territorial scope of the decision and its duration.
• (b) Facts and circumstances relied on. A description of the facts and circumstances relied on in taking the decision, including, where relevant, whether the decision was taken pursuant to a notice submitted in accordance with Article 16 or based on voluntary own-initiative investigations, and, where strictly necessary, the identity of the notifier. The identity of the notifier is not disclosed where it is not strictly necessary, or where the notifier has not consented to disclosure under Article 16(3) (typically, the identity is withheld in cases of alleged infringement of intellectual property rights or where disclosure would identify a private complainant).
• (c) Use of automated means. Information on whether the decision was taken using automated means, including whether the decision was taken in respect of content detected or identified using automated means.
• (d) Legal ground or contractual ground. Where the decision concerns allegedly illegal content, a reference to the legal ground relied on and explanations as to why the information is considered to be illegal content on that ground; or, where the decision is based on the alleged incompatibility of the information with the terms and conditions of Tanqory, a reference to the contractual ground relied on and explanations as to why the information is considered to be incompatible with that ground.
• (e) Clear and user-friendly information on the redress possibilities available to the recipient of the service in respect of the decision, in particular, where applicable, through internal complaint-handling mechanisms under Article 20, out-of-court dispute settlement under Article 21, and judicial redress.

3) Drafting standards

• The statement of reasons is written in clear and easily comprehensible language and is published in the language of the recipient where reasonably available (Article 14(1) and recital 86).
• The statement of reasons is as precise and specific as reasonably possible under the given circumstances. It states the specific item of information concerned, the specific provision of the Terms of Service or the Acceptable Use Policy violated (or the legal ground relied on for illegality), and the specific action taken.
• The statement of reasons is not used as a vehicle for marketing language or for general statements about the platform. It is a legal communication.
• Where the information has been restricted on multiple grounds (for example, both illegality and a terms violation), each ground is identified separately with its own explanation.
• Where the recipient's account is suspended or terminated, the statement specifies whether the action affects only certain features, the entire account, and whether it is temporary or permanent, and, where temporary, the expected duration or the conditions for reinstatement.

4) Statement of reasons — operational template

Tanqory operational teams populate the following structured template for each in-scope decision. Fields marked with [required] must be present in every statement; fields marked with [conditional] are populated where applicable. Free-text fields are written in the language of the recipient where reasonably available and otherwise in English with a translation offered on request.

[required] Reference identifier: SOR-<YYYYMMDD>-<short hash>
[required] Date and time of decision (UTC): <ISO 8601 timestamp>
[required] Recipient of the service: <internal account identifier; PII not published to the Transparency Database>
[required] Affected content / object:
  - Type: <post / comment / listing / file / account / payment / other>
  - Internal identifier: <opaque ID>
  - URL or surface location (where applicable): <link>
[required] Decision type (Article 17(1)):
  [ ] Visibility restriction (removal / disabling access / demotion / age gating / geographic restriction / other)
  [ ] Monetary restriction (suspension or termination of monetisation / payouts / commissions)
  [ ] Service provision restriction (feature suspension / full service suspension)
  [ ] Account suspension or termination
[required] Territorial scope of the decision:
  [ ] EU-wide
  [ ] Specific Member State(s): <list>
  [ ] Worldwide
[required] Duration: <permanent / temporary, ending on <date> / until <condition met>>
[required] Facts and circumstances relied on:
  - Source of the decision:
    [ ] Notice received under Article 16 (notice and action) — notice reference <ID>
    [ ] Order from a Member State authority under Article 9 — order reference <ID>
    [ ] Own-initiative investigation
    [ ] Trusted flagger notice under Article 22 — flagger reference <ID>
  - Identity of the notifier disclosed: [ ] yes [ ] no — reason for withholding (where applicable): <e.g., IP infringement, private complainant>
  - Summary of the facts: <plain-language description of the conduct or content>
[required] Use of automated means:
  - Was the content detected by automated means? [ ] yes [ ] no
  - Was the decision taken by automated means without meaningful human review? [ ] yes [ ] no
  - If yes, summary of the automated system: <model family / rule set / confidence threshold; no proprietary detail beyond what is required>
[required] Legal ground (illegal content) OR contractual ground (terms violation):
  - Type: [ ] Illegal content [ ] Incompatible with terms and conditions [ ] Both
  - If illegal content: legal ground relied on (statute and provision, Member State if applicable): <citation>
    Explanation of illegality: <plain-language reasoning>
  - If incompatibility with terms: provision of the Terms of Service or Acceptable Use Policy: <section reference and short quotation>
    Explanation of incompatibility: <plain-language reasoning>
[required] Decision and effect on the recipient:
  <plain-language description of what has changed for the recipient and what they can still do on the service>
[required] Information on redress (Article 17(3)(f)):
  - Internal complaint mechanism (Article 20): how to submit a complaint, deadline (at least six months), expected handling time, and a link.
  - Out-of-court dispute settlement (Article 21): notice that the recipient may select a certified out-of-court dispute settlement body, the non-binding nature of the body's decision, the costs framework, and a link to the list of certified bodies maintained by the relevant Digital Services Coordinator.
  - Judicial redress: notice of the recipient's right to seise the courts of competent jurisdiction in the EU.
[conditional] Right of the recipient to file a complaint with the relevant Digital Services Coordinator or with the European Commission, and the right to lodge a complaint with the supervisory authority for data protection where personal data are concerned.
[required] Notice of publication in the DSA Transparency Database (Article 24(5)):
  "This statement of reasons will be published in the publicly accessible database operated by the European Commission under Article 24(5) DSA, with personal data of the recipient removed."
[required] Contact for questions about this statement: dsa@tanqory.com

5) Submission to the DSA Transparency Database (Article 24(5))

Without undue delay after the decision is communicated to the affected recipient, Tanqory transmits the statement of reasons, in a machine-readable format and with the personal data of the recipient removed, to the publicly accessible database operated by the European Commission under Article 24(5) DSA. The fields submitted to the Transparency Database follow the Commission-prescribed schema (current version available at https://transparency.dsa.ec.europa.eu/page/api-documentation). Tanqory ensures that:

• the statement does not contain personal data of the recipient or of any third party other than what is strictly necessary to make the statement of reasons comprehensible;
• the URLs or content identifiers transmitted are sufficient to make the decision identifiable without re-identifying the recipient;
• machine-readable codes (decision type, legal ground category, automated-means flag, territorial scope) are populated in accordance with the database schema; and
• the timestamp of the decision and the timestamp of submission to the Transparency Database are recorded.

Tanqory monitors the submission status, retries on transient failures, and logs persistent failures for review by the Trust & Safety function.

6) Internal complaint-handling system (Article 20)

For at least six months following the decision, the recipient may submit a complaint against the decision through Tanqory's internal complaint-handling system. Tanqory:

• (a) provides electronic access to the system free of charge;
• (b) processes complaints in a timely, non-discriminatory, diligent, and non-arbitrary manner;
• (c) ensures that decisions on complaints are not taken solely on the basis of automated means and are reviewed under the supervision of appropriately qualified staff;
• (d) reverses the decision without undue delay where the complaint contains sufficient grounds to consider that the original decision was not justified; and
• (e) informs the complainant in a timely manner of the reasoned decision and of the possibility of out-of-court dispute settlement and other available remedies.

The internal complaint-handling channel is published in the EU Digital Services Act Regional Annex and is reachable at https://legal.tanqory.com/dsa/complaint or by writing to dsa@tanqory.com.

7) Out-of-court dispute settlement (Article 21)

Recipients of the service to whom a statement of reasons is addressed, and complainants whose notices submitted under Article 16 have given rise to a decision, are entitled to select any out-of-court dispute settlement body that has been certified by the Digital Services Coordinator of the Member State concerned, in accordance with Article 21(3). Tanqory engages, in good faith, with the selected body. The decision of the body is not binding on the parties (Article 21(2)), without prejudice to the recipient's right to seise the courts. Tanqory bears the fees and other reasonable expenses incurred by the body in line with Article 21(5), subject to the conditions therein. A current list of certified bodies is maintained by the European Commission and by the relevant Digital Services Coordinators.

8) Special cases and exclusions

• Manifestly illegal content involving criminal offences (Article 18): where Tanqory becomes aware of any information giving rise to a suspicion that a criminal offence involving a threat to the life or safety of a person or persons has taken place, is taking place, or is likely to take place, Tanqory promptly informs the law enforcement or judicial authorities of the Member State or Member States concerned. The statement of reasons issued to the recipient in such cases may be subject to lawful delay where disclosure would jeopardise the investigation; the rationale for any delay is logged internally.
• Trusted flagger notices (Article 22): notices submitted by trusted flaggers are processed with priority. Statements of reasons issued in response identify the trusted flagger status (without disclosing the flagger's identity where strictly necessary).
• Repeat infringers (Article 23): before suspending the provision of the service to a recipient who frequently provides manifestly illegal content, Tanqory issues a prior warning that complies with Article 17 and includes information about the suspension regime under Article 23.
• Deceptive high-volume commercial content (Article 17(2)): statements of reasons are not issued for content that is deceptive high-volume commercial content. The classification of such content is logged internally and is subject to periodic review.

9) Recordkeeping and transparency reporting (Article 15 and Article 24)

All statements of reasons and the underlying decision records are retained for the periods required by the DSA and by the Tanqory retention schedule. Aggregate counts of decisions taken under Article 17(1) and of complaints received under Article 20, broken down by decision type, legal/contractual ground, use of automated means, and territorial scope, are published in the periodic DSA transparency report under Articles 15 and 24, with the qualifications applicable to Tanqory's classification under the DSA (online platform, very large online platform, or otherwise).

10) Languages and accessibility

Statements of reasons are issued in the language of the recipient where reasonably available, and in any event in a language compatible with the recipient's interface language. Accessibility features (screen-reader compatibility, plain-language summaries) are applied so that recipients with disabilities can access the statement and the redress channels on equal terms.

11) Relationship with other Tanqory documents

This template is incorporated by reference into the EU Digital Services Act Regional Annex (annex/regions/digital-services-act-eu.md). It supplements the Acceptable Use Policy and the Terms of Service. In case of conflict between this template and another Tanqory document with respect to the form and content of a statement of reasons under Article 17 DSA, this template prevails.

12) Contact

• DSA contact point (Article 11 / Article 12 single point of contact): dsa@tanqory.com
• Article 13 representative in the Union: Tanqory OÜ, Ahtri tn 12, Kesklinna linnaosa, Harju maakond, 10151 Tallinn, Estonia
• Internal complaint mechanism (Article 20): https://legal.tanqory.com/dsa/complaint
• Out-of-court dispute settlement (Article 21): the recipient may select any certified body listed by the relevant Digital Services Coordinator

13) Change history