ClearLaunch
Feature CheckerRegulations & PoliciesEnforcementRadarVendorsChangelogGuides
FAQ
← All Controls

Ranking transparency disclosure

ranking-transparency-disclosureDomain: marketplace-platformType: policy

Description

Ranking transparency is the disclosure obligation that catches the algorithm that orders search results, product listings, and feeds for users, and that has been spreading across regulatory regimes faster than most platforms have adapted. The EU Platform-to-Business Regulation requires online intermediation services to disclose the main parameters that determine ranking, the relative importance of each, and the reasons for that importance, in plain language and in the terms of service. The Digital Services Act extends an analogous disclosure to recommender systems on online platforms and very large online platforms, with the additional obligation that VLOPs offer at least one non-profiled alternative. The operational tension is the parameters question: most production ranking systems involve dozens of features and a model that is not parameter-by-parameter inspectable, which is why the disclosure standard is main parameters in their relative importance rather than a feature-by-feature accounting. The defensibility argument is whether the disclosure plausibly describes how the system actually works, not whether it captures every feature. The other piece that consistently surprises platforms is the paid-promotion disclosure: any commercial influence on placement (sponsored, promoted, advertising consideration of any kind) has to be disclosed at the listing level, not only in the global terms, and the disclosure has to be visible at the point the user encounters the placement.

Applicability

Applies when: business model role is intermediary or mixed.

How predicates are evaluated

Required by (4 regulations)

  • DSA

    Article 27 — recommender-system transparency for online platforms.

    Regulation (EU) 2022/2065 of the European Parliament and of the Council (Digital Services Act)

  • Omnibus

    Consumer rights on personalized rankings.

    Directive (EU) 2019/2161

  • EU P2B

    Article 5(1) — main parameters of ranking disclosed in terms with relative importance; remuneration-influence disclosed where applicable. Article 5(2) extends parallel obligation to online search engines for corporate-website results.

    Regulation (EU) 2019/1150

  • EU DMA

    DMA Article 6(5) — ranking-fairness obligation paired with the disclosure regime; for designated gatekeepers, the obligation is ex-ante structural rather than transparency-only.

    Regulation (EU) 2022/1925

Fulfilled by (1)

  • In-house build · low effort

ClearLaunch does not accept payment from vendors. Methodology.

Evidence formats

  • ranking-parameters page
  • paid-promotion disclosure
  • A/B test logs

ClearLaunch provides legal information based on publicly available regulatory sources. It does not constitute legal advice and does not create an attorney-client relationship. Consult a licensed attorney in your jurisdiction before making compliance decisions.

ClearLaunch

Regulatory intelligence for people who ship products.

Tools
Feature CheckerRegulations & PoliciesVendorsGuidesFor LegalFor EngineeringFor ExecutivesFor Investors
About
AboutMethodologyChangelogFAQRegulatory UpdatesClearLaunch on LinkedIn
Legal
Terms of ServicePrivacy PolicyHow we handle your dataCoverage scope & limitations

Built by Neel Patel, in-house game counsel. Games touch more compliance domains at once than anything else in tech. That's what ClearLaunch was designed around.

ClearLaunch provides legal information based on publicly available regulatory sources. It does not constitute legal advice and does not create an attorney-client relationship. Consult a licensed attorney in your jurisdiction before making compliance decisions. Operated by a Washington-licensed attorney. Not licensed in California or other US states. ClearLaunch provides legal information; consult a licensed attorney in your jurisdiction. Data reviewed through March 2026. Methodology

© 2026 ClearLaunch · Terms · Privacy