legal
Telegram Group Inc.
Case Id: 32
Default Decision
In its capacity as an out of court dispute settlement body under Art 21 of the digital services act, ADROIT, based on the statements submitted by the parties, held that
1. The admissible complaint is upheld.
2. The Respondent’s moderation decision against the Complainant was not justified.
3 The Respondent bears the cost of the proceedings.
A. Parties
The Complainant is O, residing at
The Respondent is Telegram Group Inc , with registered address at 71 Avenue Huart Hamoir, 1030 Schaerbeek, Belgium
B. Procedural History
The Complaint was filed with ADROIT on the 27 Mar 2026 by online submission In accordance with the Rules of Procedure, ADROIT formally notified the platform provider of the Complaint and hence the case was formally opened. This Rules of Procedure are premised on fairness, equity, and good faith participation by both parties and require ADROIT to make every reasonable effort to conclude proceedings within ninety (90) calendar days from receipt of the complaint, subject to extension where justified
In line with these Rules, the Respondent was duly notified of the complaint and afforded the opportunity to submit observations within the prescribed fourteen (14) day period. Following the failure to provide a due and/or proper substantive reply, insofar as it failed to engage with the nature of the dispute or the merits of the adjudication process, and in order to avoid delaying the procedure and risking rendering the process ineffective, ADROIT’s Rules expressly provide for the possibility of deciding the dispute by default, at its sole discretion, on the basis of the information available on the file. The adoption of a default decision in such cases does not operate as an automatic sanction against a party, but rather as a procedural mechanism designed to safeguard the integrity, efficiency, and conclusiveness of the dispute settlement mechanism established under Article 21 DSA.
Having exhausted reasonable procedural measures to secure the Respondent’s substantive engagement, and in order to avoid an indefinite suspension of the proceedings incompatible with the statutory efficiency requirements applicable to certified out-of-court dispute settlement bodies,
ADROIT determined that the conditions for issuing a default decision were met. The case was therefore assigned to an impartial and independent decision-maker for resolution on the basis of the submissions and evidence available on the record, the applicable legal framework, the Respondent’s terms and conditions, and ADROIT’s Rules of Procedure
C. Facts of the Case
The Complaint challenges a moderation inaction/decision of the Respondent, which affected the Complainant as an active recipient of the service on the Respondents platform during that time.
Complainant’s submission
The complainant states that their professional tool, “@contentremoval bot,” was suspended by Telegram on 18 February 2026 without prior notice or explanation
The complainant explains that the bot functions as a lawful utility designed to assist with copyright and impersonation verification. It enables users to identify potentially infringing links and redirects them to the official platform “Remov.ee” in order to initiate formal takedown procedures. The complainant emphasizes that the bot does not host or distribute illegal content, but is instead intended to help combat such content
The complainant further notes that no statement of reasons was provided for the suspension, and no internal appeal mechanism or opportunity to contest the decision was made available. The complainant considers this a procedural deficiency.
In addition, the complainant states that, as an Digital Services Act Trusted Flagger, the suspension of their professional infrastructure has significantly impacted their ability to process and report illegal content effectively The complainant therefore requests reinstatement of the bot and a formal
explanation regarding the reasons for its suspension.
Respondent’s submission
The Case Synopsis was duly notified to Discord on 30 March 2026 However, the platform failed to submit any response, observations, or supporting evidence in relation to the complaint.
D. Admissibility
The Complaint is admissible
E. Merits of the Case
The present dispute concerns a moderation decision as per Article 20(1) DSA, namely the suspension of the Complainant’s Telegram bot, “@contentremoval bot”, on 18 February 2026. As set out in the procedural history, the Respondent was notified of the complaint and given the opportunity to provide the factual, contractual and technical basis for the contested decision The Respondent did not submit a due, proper and substantial response. ADROIT therefore assesses the dispute on the basis of the material available in the file.
A default decision does not entail automatic acceptance of the Complainant’s position. However, in the absence of a due response from the Respondent addressing the claims made by the user and justifying the moderation decision, ADROIT cannot verify any factual basis, policy analysis, enforcement metadata or internal review information that has not been placed before it.
On the basis of the evidence available, it cannot be established why the Respondent considered the bot to be incompatible with Telegram’s Terms of Service or any applicable bot, abuse, copyright, impersonation, spam, automation, or platform-integrity rule The Respondent has not engaged in
the present case nor has the Respondent provided moderation notes, enforcement metadata, technical indicators, notice records, internal review information, or any explanation
In the absence of such information, ADROIT cannot verify if the enforcement action was correctly applied On the basis of the available evidence, ADROIT concludes that the Respondent has not justified the contested moderation decision.
F. Decision and Conclusion
Accordingly, ADROIT upholds the Complainant’s position
G. Cost Decision and Information on Legal Remedies
The Respondent bears the cost of the proceedings. According to ADROIT's Fee Model, the Respondent is charged for this Decision with the Administrative Fee (ADROIT Fee Model, EUR 149 57), as well as the Processing Fee (EUR 349.77), amounting to a total Fee of EUR 499,34.
This Decision can be appealed one week after it has been issued
As an out-of-court dispute settlement decision under the DSA, this decision is not binding according to Art. 21 sec. 5 DSA. It does not preclude either party from pursuing further legal remedies.
Adroit, June 18, 2026