Platform to Business Regulation

P2B Complaint Handling Annual Report

This report is published in compliance with the Platform to Business Regulation 2019/1150 (“P2B Regulation”), which came into effect on July 12, 2020, and was retained in the laws of the United Kingdom following its departure from the European Union.

The P2B complaint form allows Shopify merchants to submit complaints through the P2B Form in the following categories:

• Concerns related to Shopify’s compliance with its obligations as set out in the P2B Regulation
• Technological issues directly related to Shopify’s provision of the P2B Services
• Decisions made by Shopify regarding its P2B Services provisions

This report provides details on the P2B complaints received through the P2B form, categorization of the complaints, the average time taken to process complaints, and a summary of complaint outcomes as defined by the P2B Regulation.

The most frequent reported issues pertained to payout-related issues and problems concerning two-factor authentication (2FA).

Complaint Handling Annual Report Jan – Dec 2024
Number of P2B Complaints	4
Enforcement Decisions Upheld	4
Enforcement Decisions Overturned	-
Average time to process complaints	2.7 days1

1. The average processing time reflects that many P2B complaints were addressed concurrently through other support and escalation processes. In some cases, complaints were resolved through these channels before the P2B form ticket was resolved.

Digital Services Act

Information on Active Monthly Users for purposes of the Digital Services Act

The Digital Services Act (DSA) creates new obligations for certain digital service providers within the European Union (EU). Among these obligations, Article 24(2) of the DSA requires providers of 'online platforms' and 'online search engines' to publish 'information on the average monthly active recipients of the services' in the EU. This information is used to determine whether an online platform is a 'very large online platform' (VLOP), meaning it reaches an average of at least 45 million users per month in the EU.

To the extent that any of Shopify's offerings may be considered 'online platforms' under the DSA, we concluded that during the period January 1, 2024 to December 31, 2024, the average number of monthly active recipients of those services in the EU was well below the 45 million user threshold for being designated as VLOPs.

We will continue to monitor the number of average monthly active recipients of any potentially relevant services in the EU, and publish updated information in accordance with Article 24(2) of the DSA.

Shopify's Single Designated Point of Contact for Inquiries under Article 11 of the DSA is consumerprotection@shopify.com. This email address is reserved for government authorities authorized to act pursuant to Art. 9 of the Digital Services Act. If you are not an authorized government authority, please use our "Report an Issue" form at https://shopify.com/legal/report-an-issue. Additionally, if you are looking to submit a legal request for information to Shopify, please visit our Guidelines for Legal Requests for Information.

Shopify's 2025 Digital Services Act Transparency Report

Introduction

Shopify is a Canadian company that provides essential internet infrastructure for commerce, offering trusted tools to start, scale, and run a business. Entrepreneurship is at the center of Shopify's mission to make commerce better for everyone.

Shopify's core offering is a single integrated, easy-to-use back-end that merchants can use to manage their business across multiple sales channels. This includes a hosting service that allows merchants to build and modify their own online stores, including with third party apps. Shopify also maintains a sales channel called "Shop", which Shopify merchants can use to sell their products to consumers.

Information in relation to Shopify's core offering - Article 15(1)(c)

Enforcement

Shopify's review processes ensure appropriate enforcement of the Terms of Service for Shopify's core offering. Depending on the nature of the issue, Shopify may take a number of actions, including:

• Asking merchants for additional information regarding the complaint.
• Restricting shipping settings to prevent the sale or shipment of certain infringing products to specific regions.
• Engaging with service recipients to encourage voluntary removal of violating content.
• Removing violating content from online stores.
• Preventing non-compliant service recipients from receiving payments, processing charges, initiating refunds, or transferring funds.
• Temporarily restricting access to a store's management interface.
• Temporarily locking their online stores.
• Terminating their account.

Actions are calibrated to the severity and number of violations by a merchant. If a terms violation results in a restriction placed on an EU merchant's shop, the merchant can dispute that restriction.

People

Shopify's internal enforcement teams have procedures to ensure consistent and appropriate decision-making. These teams iterate on policies and processes, to incorporate learnings and changes to underlying terms and conditions.

Tools

Shopify uses a combination of machine learning and human analysts to enforce its policies. Shopify's automated tools are tested extensively before they are deployed.

Information in relation to Shopify's core offering - Article 15(1)(a)

Number of notices received from Member States' authorities

Shopify's legal access request form provides a path for law enforcement officials and regulators to request information held by Shopify or report a store for illegal activity or for otherwise violating Shopify's Acceptable Use Policy. Shopify balances our legal obligations, the requesting party's needs, and the interests of our merchants, their customers, and/or our partners when we receive legal requests for information.

Article 9 - orders to act against illegal content

In 2024, Shopify received 4 Article 9 orders from France and none from any other member state authorities.

Article 10 - orders to provide information

In 2024, Shopify received 804 Article 10 orders from member state authorities. The median time to confirm receipt is 0 hours. The median time to give effect to the order, as applicable, is 43 hours.

Information requests by member state authorities

Information in relation to Shopify's core offering - Articles 15(1)(b) and (d)

Number of notices submitted in accordance with Article 16

In 2024, Shopify received 34,238 notices from complainants identified as being in the EU and took action in 10,071 of those cases. Shopify also received 2,522 notices from EU complainants through our internal complaints handling system in response to actions taken. Shopify did not receive notices from trusted flaggers.

Every notice submitted in accordance with Article 16 was processed manually. The median time for taking action was 45 hours.

Own-initiative

In 2024, Shopify placed 431,786 restrictions using automated means. Of those, 12,176 were subsequently reversed upon appeal.

Information in relation to Shop - Articles 15(1)(c) and (e)

Enforcement

Shop's review processes are carefully calibrated to ensure appropriate enforcement of Shopify's Terms of Service and Shop's merchant guidelines. Depending on the nature of the issue, Shop may take a number of actions, including:

• Restricting shipping settings to prevent the sale or shipment of certain infringing products to specific regions.
• Restrict the visibility of products on Shop.
• Remove the merchant from Shop.

Actions are calibrated to the severity of the violation and number of violations by a merchant. If a terms violation results in a restriction placed on an EU merchant's use of Shop, the merchant can dispute that restriction. Complaints through Shop's online reporting form are processed via human review.

People

Shop's internal enforcement teams have procedures in place to ensure consistent and appropriate decision-making. These teams iterate on policies and processes, to incorporate learnings and changes to underlying terms and conditions.

Tools

Shop uses a combination of machine learning and human analysts to enforce its policies. Shop's automated tools are tested extensively before they are deployed.

Information in relation to Shop - Articles 15(1)(a), (b), and (d) and Article 24(1)

Number of notices received from Member States' authorities

In 2024, Shop did not receive a request from any member state authority.

Number of notices submitted in accordance with Article 16

In 2024, Shop received 1,278 notices from complainants identified as being in the EU and took action in 115 of those cases. Shop also received 2,730 notices from EU complainants through its internal complaints handling system in response to actions taken. Shop did not receive notices from trusted flaggers.

Every notice submitted in accordance with Article 16 was processed manually, and the median time for taking action was 30 hours.

Own-initiative

In a retrospective review, 22,725 removals of products from Shop in the EU for violating Shop's policies were identified. Prior to 2025 Shop did not have data sufficient to track automated actions contemporaneously. As of the date of this report, Shop is submitting statements of reasons to the Commission's DSA Transparency Database.

Out of court dispute settlement

As of the date of this report, Shop has not been involved in any out-of-court dispute settlement processes.

Measures and protections against misuse

If service recipients post content that violates our Acceptable Use Policy or our Terms of Service, we take the appropriate enforcement action as referenced above. This may include suspending or disabling accounts where service recipients persistently or severely violate our terms.

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Footnote - A report in accordance with Articles 15 and 24 of the EU Digital Services Act (DSA) - covering January 1, 2024 to December 31, 2024. In some sections, we note data limitations or exceptions. This report should not be used for any purpose other than to fulfil Shopify's transparency obligations under the DSA.