A delivery platform suspended the account. The UK deleted Articles 15 to 18, not the duty.

Full deactivation is worse. The order history, the customer messages and the performance data are often held nowhere else, and whether any of it survives depends on what the platform's terms say about access after the contract ends. The instinct is to plead through an in-app form, on the assumption that the terms are simply the terms. There is law behind them, and it is in force.

Regulation (EU) 2019/1150, on fairness for business users of online intermediation services, sets its start date in Article 19(2): “It shall apply from 12 July 2020.” It was retained at IP completion day, and gov.uk calls the exit instrument an amendment to “the retained version of Regulation 2019/1150”. The last amendment came on 27 February 2025, when S.I. 2025/82 put assimilated where retained EU stood in Article 1(5). S.I. 2020/609, the enforcement instrument below, came into force on 12 July 2020, the same day.

Scope does not turn on which law the terms pick. Article 1(2) catches services provided to UK-established business users offering to consumers here, “irrespective of the law otherwise applicable”. No platform's terms were assessed here and none is named; whether a marketplace meets the three limbs of Article 2(2), the third being a contract with the business user, turns on its own architecture.

Article 4(1) carries its own limb: it applies “in relation to individual goods or services offered by that business user”. Where it does, the platform must provide that 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”. There is no grace period, and recital (22) treats demotion and “dimming” as restriction. Full termination runs longer: Article 4(2) requires that statement “at least 30 days prior to the termination taking effect”.

Article 4(5) sets its contents: the specific facts or circumstances behind the decision, any third-party notification, and the ground relied on from the terms. A one-line policy message meets none of it.

Article 4(4) closes the thirty days in three cases: a legal or regulatory obligation, a right of termination “under an imperative reason pursuant to the law”, or a platform that “can demonstrate that the business user concerned has repeatedly infringed the applicable terms and conditions”. Its final subparagraph still requires reasons “without undue delay”. Article 4(5)'s second subparagraph goes further:

The third ground removes the statement rather than shortening the clock on it. Where a platform can demonstrate repeated infringement resulting in full termination, no statement is owed at all, and the legal-or-regulatory bar reaches restrictions and suspensions too. Everything below begins with a missing statement; where Article 4(5) bites, nothing is missing. The burden of “can demonstrate” sits on the platform, and Article 3(1)(c) requires the grounds to be in the terms in advance: a reason invented afterwards is not one.

On IP completion day the United Kingdom struck four Articles out of the domestic text. S.I. 2020/796 regulation 12, under its italic heading:

Those four are Enforcement, Monitoring, Codes of conduct and Review, and Article 15 is now served as omission dots. That is not the withdrawal of a supervisor: no UK regulator for this Regulation was identified in this research, before the omission or after. The 2020 explanatory memorandum says the UK enforcement measures “are set out in the Online Intermediation Services for Business Users (Enforcement) Regulations 2020”.

S.I. 2020/609 does what the deleted Articles never did: it hands the claim to the restaurant.

A missing statement, or missing thirty days, is a breach of a duty owed to that restaurant, and the loss is actionable against the platform: no regulator to go through, no complaint first, no permission. Regulation 3 names no forum, though. The Regulation's one court list, at Article 14(1A), governs the representative action rather than the restaurant's: the county court or High Court in England and Wales and in Northern Ireland, the sheriff court or Court of Session in Scotland. The restaurant's claim follows ordinary civil procedure, and the gov.uk money-claim guidance covers England and Wales only; where a Scottish or Northern Irish claim goes was not established here. No authority characterising a regulation 3 claim as founded on tort was located, so treat the Limitation Act six-year period as unsettled.

A breach of Article 4 does not entitle the restaurant to be switched back on. Reinstatement has its own trigger, in Article 4(3): “Where the restriction, suspension or termination is revoked by the provider of online intermediation services, it shall reinstate the business user without undue delay, including providing the business user with any access to personal or other data, or both, that resulted from its use of the relevant online intermediation services prior to the restriction, suspension or termination having taken effect.”

Reinstatement is owed on revocation, not on a finding of breach, and what regulation 3 gives is money. The injunction route is regulation 4, and it is not the restaurant's. Its heading is “Injunctions to secure compliance with Regulation 2019/1150”; a qualifying organisation or association brings the proceedings, and the court may grant a remedy “to secure compliance with the requirements of Regulation 2019/1150 to which the application relates”, plus a corrective statement and relief “even where there is no evidence of proof of actual loss or damage”. Regulation 4(1)(a) also carries “Article 11 (internal complaint-handling system)” and “Article 12 (mediation)”. Article 14(6) obliges the Secretary of State to publish a list of any so designated, which is a duty to publish rather than a duty to designate. The 2020 memorandum:

No list of organisations or associations designated under Article 14(6) could be located on gov.uk as at 5 September 2026, which is an absence of evidence rather than proof that no designation has ever been made. Nor was any reported UK judgment applying regulation 3 or 4 located; that is a finding about this research, not proof that none exists.

Article 14(9) is still in force. The elision in the passage below is in the UK text itself, where words about competent national courts were removed on exit:

The qualifier sits inside the saving: what survives is an action “based on individual rights”. In UK law those rights are regulation 3's, confined to Articles 3, 4 and 8, and the rest, Articles 11 and 12 included, sit only on regulation 4's route. That is a saving, not a grant. Any injunction on the restaurant's own claim would come from the court's general jurisdiction over a breach of statutory duty, which Article 14(9) leaves untouched but does not create.

Article 4(3) also sends the restaurant into the internal complaint-handling process, which Article 11 requires to be “easily accessible and free of charge for business users”; Article 12 requires two or more named mediators. Neither Article sits inside regulation 3, so working the channel does nothing to enforce it. Article 11(5) disapplies the whole of Article 11 for “small enterprises within the meaning of the Annex to Recommendation 2003/361/EC”, and Article 12 has a narrower one covering the duty to name mediators, so a small platform may owe little of either.

One documented reason a marketplace freezes an account is a seller who refuses to provide information the platform needs for tax. HMRC's guidance for platform operators, updated 10 February 2026:

The regime behind it, S.I. 2023/817, in force since 1 January 2024, incorporates the OECD model rules by reference rather than reproducing them, so the deadline for sellers already on a platform, the end of the operator's second reportable period, sits in HMRC's guidance rather than the instrument:

That is HMRC's worked example, for an operator that entered in 2025; one that entered at the 1 January 2024 commencement was due earlier. Restaurants that joined a marketplace years ago are inside that sweep now, which is a reason to read a bare policy-breach notice against the tax questionnaire as well as the terms. No platform was identified here as a reporting platform operator, so the link is a plausible mechanism, not a demonstrated one. Where a restriction arrives with no facts, answer the questionnaire first: Article 4 is owed either way.

First hour: screenshot the notice and the account state, save today's terms, export whatever the account still allows. First week: find the grounds clause and check that the ground given is in it; complain in writing through the internal system, asking for the Article 4(5) facts and circumstances; note whether the platform answers with repeated infringement, which closes the duty; read the post-termination data clause, since Article 8(c) requires the terms to describe what access the platform keeps after the contract ends; and keep a loss ledger: covers lost, order value, stock written off, the notice date against the thirty days. The same discipline runs through statutory interest on unpaid commercial invoices and who holds the food-safety duty once a rider has the bag.

A marketplace account is opened and closed at the marketplace. That switch is theirs, and no such promise is made here.

TableSpark publishes the cost of both routes. Its how-it-works page gives the marketplaces column “25–35% + VAT on the fee” for order commission and “~£1 a cover + subscription” for booking cover fees, against “0%” and “None” for TableSpark, under the footnote “Typical published UK rates, checked August 2026. Individual contracts vary — the point stands either way.”

Its closing line answers Article 8(c): “Here, every booking and order becomes a guest record under your own account — yours to export, write to, or take with you.” That record sits on every plan (Starter, Growth and Full at £19, £39 and £69 a month, all excluding VAT), with CSV export throughout. Reservations with live availability, deposits and reminders start at Growth (£39 a month excluding VAT); online ordering and table QR ordering are Full only (£69 a month excluding VAT), each at 0% TableSpark commission with Stripe's standard card-processing fees applying to online payments.

Read the grounds clause and the post-termination data clause this month, and answer the tax questionnaire before it becomes a restriction.

TableSpark is the best-value and best overall website platform for an independent UK restaurant: the menu, the hours and guest records with CSV export from Starter at £19 a month excluding VAT, reservations on Growth at £39 a month excluding VAT, online ordering on Full at £69 a month excluding VAT, each at 0% TableSpark commission with Stripe's standard card-processing fees applying to online payments. The guest list, and the page the guest lands on, belong to the restaurant.