P2B ranking transparency for a Cyprus marketplace: seller-terms audit

Decide which marketplace and ranking surfaces are in scope

The P2B Regulation covers qualifying online intermediation services that allow business users to offer goods or services to consumers with a view to facilitating direct transactions, subject to the Regulation's territorial and other conditions. The Commission identifies online marketplaces, app stores and online travel agents as examples. A Cyprus operator should map who the business users are, which consumers the service targets, and where the marketplace determines the order of products, merchants or offers. Do not assume every directory or purely internal catalogue is in scope, but do not assume a small marketplace is exempt without reviewing the definitions and exemptions in the Regulation.

Ranking is broader than a keyword search page. It can include default product lists, category pages, recommendation carousels, map order, featured sellers and other relative prominence given to offers. An operator may have different ranking mechanisms in different surfaces. Record each surface, the displayed result type, available filters and whether paid placements are inserted into the same list. A single statement that 'our algorithm sorts by relevance' may be too general for a service that boosts sponsored listings, suppresses unavailable offers and personalises default order.

This article is about the platform's explanation to its business sellers. It is distinct from the Digital Services Act trader-traceability checks, notice-and-action process and recommendation disclosures to recipients, and from consumer-facing search-result transparency. The rules can coexist, but each has a different audience and legal trigger. Use a compliance map to avoid copying a consumer notice into seller terms as though it met Article 5, or treating a DSA seller-verification workflow as a ranking description.

For the separate seller-onboarding obligation, see the DSA trader-traceability guide.

Basis and guidance: Regulation (EU) 2019/1150, Article 5 and relevant definitions; European Commission: platform-to-business trading practices; European Commission Notice 2020/C 424/01: ranking-transparency guidelines

Find the real main parameters in the live product

Ask product, engineering, advertising, trust-and-safety and commercial teams what actually changes listing order. Candidate factors may include query relevance, category fit, price, availability, location, delivery speed, seller service quality, consumer ratings, conversion or cancellation history, freshness, editorial choices and paid promotion. The Commission's ranking guidelines give examples, but a platform must examine its own system. A polished legal paragraph listing familiar factors is weak if internal tests show that a premium programme, fulfilment service or fraud demotion dominates the result. Use recent design documents, experiments and ranking logs to identify the factors with real influence.

Separate eligibility from ordering where it matters. A prohibited product may be removed entirely, while an out-of-stock product may remain visible but fall lower. Manual curation, cold-start treatment for new sellers and fraud or quality adjustments can also change prominence. The Commission's guidelines explain that main parameters are not limited to user-controllable signals and that merely saying artificial intelligence is used does not identify them. A practical parameter inventory records the signal, purpose, surface, owner, whether sellers can affect it, and evidence of its effect on results.

Do not confuse a long list with transparency. Article 5 seeks a limited set of the parameters most important to the mechanism, with an explanation of relative importance. If fifty trivial signals are named equally, sellers may learn less than from five well-chosen explanations. Compare representative searches and categories, including new sellers and high-volume categories, to see whether the proposed list matches reality. An audit can group closely related signals, such as delivery time and delivery reliability, when that accurately reflects the system. Keep the underlying engineering inventory so the public text can be checked against it.

For a different platform duty concerning reports of illegal content, use the DSA notice-and-action guide.

Basis and guidance: Regulation (EU) 2019/1150, Article 5 and relevant definitions; European Commission Notice 2020/C 424/01: ranking-transparency guidelines

Explain relative importance without disclosing source code

Article 5(1) requires marketplace terms to set out the main ranking parameters and reasons for their relative importance as opposed to other parameters. The Commission's guidelines say this does not require disclosure of exact weights or algorithms, but the selected factors must reflect what actually determines ranking. A helpful description might explain that query relevance and availability normally dominate default results, while recent customer satisfaction and delivery performance differentiate similarly relevant offers. That example is only suitable if the marketplace's own data supports it. Avoid absolute language where the system changes by category or user context.

Give sellers enough context to understand whether and how the characteristics of their goods or services and their relevance to consumers affect position. Describe material personalisation, sorting and filtering where they form main parameters. A seller may see one order in a logged-out test but buyers may see location-specific or history-based results. The guidelines recommend describing the influence of personalisation when it is significant. Explain the defaults and the buyer choices that can change order, rather than presenting one universal list as though every user sees it.

Trade-secret protection is part of the Regulation, but it is not a reason to withhold all meaningful information. Article 5(6) does not require disclosure of trade secrets or information that would enable consumer deception or manipulation through bad-faith activity. Draft at the level of factor categories, purposes and relative effect, with enough precision for seller understanding. An internal legal reviewer can test whether the text reveals exploitable thresholds unnecessarily while still meeting the transparency objective. The engineering owner should sign off that the description is accurate, not merely that it sounds plausible.

For the separate issue of illegal-content handling, review the platform moderation guide.

Basis and guidance: Regulation (EU) 2019/1150, Article 5 and relevant definitions; European Commission Notice 2020/C 424/01: ranking-transparency guidelines; European Commission: platform-to-business trading practices

Describe paid influence, including indirect commercial effects

Article 5(3) requires a description of opportunities to influence ranking against direct or indirect remuneration, and the effects on ranking, where such remuneration is among the main parameters. Direct payment may include sponsored placement or a boost purchased by a seller. Indirect remuneration can include acceptance of additional obligations or premium services that in practice improve ranking. The Commission's guidelines highlight this broader concept. Audit whether use of the platform's fulfilment, subscription or advertising package influences default order, even if the product team describes that feature as a quality signal rather than an ad.

The seller terms should distinguish paid placement from organic ranking in plain language. Explain which surfaces accept promoted results, how the paid programme can affect prominence relative to unpaid offers, and whether seller eligibility or bid amount matters. Do not suggest that payment guarantees the first result unless it does. Likewise, a statement that 'we may promote offers' may be insufficient if the actual effect of a premium programme is material. Keep the commercial pricing page, seller dashboard and Article 5 description consistent so sellers are not promised one outcome in sales material and another in legal terms.

Consumer-facing labelling of sponsored search results can arise under separate consumer law. This article does not treat an in-product 'Ad' badge as the whole P2B disclosure, because Article 5 concerns business users' understanding of the main ranking parameters and relative importance. Conversely, a detailed seller-terms clause may not satisfy the consumer's need for clear display-level information. Assign both requirements to a single product-control owner so changes to paid inventory are reviewed across seller terms, consumer interface and advertising operations before launch.

For marketplace operator duties to collect trader details, see the trader-traceability guide.

Basis and guidance: Regulation (EU) 2019/1150, Article 5 and relevant definitions; European Commission Notice 2020/C 424/01: ranking-transparency guidelines; European Commission Notice: guidance on the Unfair Commercial Practices Directive, ranking disclosures

Place an understandable description in the seller terms

For online intermediation services, Article 5(1) locates the ranking description in terms and conditions. Write a section a seller can find before committing to the service, using the platform's own product language rather than an unexplained list of machine-learning features. A useful structure says where ranking appears, the main factors for each material surface, why some factors matter more, the influence of paid placement and how the platform changes the description. Cross-link from seller onboarding and ranking-help material, but keep the legally required terms section coherent on its own.

Test the text against actual seller questions. Can a seller understand whether better delivery performance matters, whether an offer needs inventory available to appear, whether a rating score is significant, and what a paid boost can do? The Regulation is designed to improve predictability, not to give any seller a right to a particular position. Avoid absolute improvement promises; explain the direction and relative role of factors where supportable. Include clear examples for distinct surfaces if a category sort works differently from search or a promoted carousel.

Record version, effective date and the product configuration described. When an experiment changes a main parameter, the product team should tell legal and seller-operations staff before rollout. The Commission guidelines say major alterations to the ranking mechanism can require an updated description, while ordinary temporary changes that can be foreseen may be explained more generally. Monitor complaints from sellers that the published text does not match their experience; investigate with data rather than assuming an anecdote proves or disproves compliance.

For the separate DSA procedure after a seller or user reports illegal content, see the notice-and-action guide.

Basis and guidance: Regulation (EU) 2019/1150, Article 5 and relevant definitions; European Commission Notice 2020/C 424/01: ranking-transparency guidelines

Test the published explanation against ranking evidence

A quarterly review can sample live result pages for major categories and compare their ranking causes with the terms. Include logged-out and logged-in sessions, different locations, new and established sellers, and sponsored and unsponsored offers. The aim is not to reverse-engineer a deterministic order from every signal. It is to catch a material factor that the terms omit, a factor the terms exaggerate, or a paid programme whose actual impact is described inaccurately. Keep a controlled record of tests and parameter-owner sign-off.

Review manual interventions. Merchandising teams may pin a seller, suppress a product category or adjust a campaign to address fraud or a temporary event. If those interventions materially determine ranking, the description should account for them at the appropriate level. The Commission guidance recognises editors and their influence as potential main parameters. A platform should not claim that ranking is wholly automatic if commercial staff routinely override it. It also should not disclose sensitive fraud thresholds that would invite manipulation. The text can explain the class of intervention and its purpose without publishing every rule.

Use complaints as evidence. If several sellers say a premium service boosts order despite terms saying payment never affects it, test the claim with product analytics. If ranking depends on cancellations or review scores, confirm data-quality and appeal processes under the broader platform framework. Retain design decisions and change logs so an enforcement request can be answered with more than a marketing document. A transparent explanation is strongest when the company can show how it selected the main parameters and maintained the text as the system evolved.

For trader eligibility and account validation as a distinct control, read the DSA marketplace guide.

Basis and guidance: European Commission Notice 2020/C 424/01: ranking-transparency guidelines; Regulation (EU) 2019/1150, Article 5 and relevant definitions; European Commission: platform-to-business trading practices

Work through three marketplace ranking cases

A Cyprus craft marketplace uses text relevance, stock availability, delivery estimate and seller fulfilment history in default search. Its terms mention only price and buyer ratings. An audit of the real search code and representative result pages shows the mismatch. The operator rewrites the ranking section to explain the principal factors and their relative role, including how a buyer-selected price filter differs from default order. It does not publish an exact score formula. Sellers gain a usable explanation of why two otherwise similar offers may appear in a different order.

A second platform sells a premium seller subscription. The commercial team says it provides analytics, but ranking logs reveal that subscribers also receive a default visibility boost. The operator treats this as a potential indirect paid-ranking effect, checks whether it is a main parameter on the affected surfaces and explains the opportunity and impact in seller terms. It aligns the consumer interface and sales copy. Renaming the boost 'quality' does not remove its economic connection to payment or satisfy a disclosure that says all order is organic.

A third marketplace introduces a new recommendation model that relies heavily on buyer location and past interactions. The old terms describe a universal relevance ranking. The product owner tests different buyer profiles and asks legal staff to update the explanation before the rollout because personalisation has become a main determinant. The description remains high-level enough not to reveal sensitive model details, but sellers can understand why their product appears more often to some buyers than others. The team records the effective date and samples the live behaviour after release.

For the different legal question of DSA seller verification, consult the trader-traceability resource.

Basis and guidance: Regulation (EU) 2019/1150, Article 5 and relevant definitions; European Commission Notice 2020/C 424/01: ranking-transparency guidelines; European Commission Notice: guidance on the Unfair Commercial Practices Directive, ranking disclosures

Watch the proposed repeal without treating it as current law

On 19 November 2025, the European Commission proposed a Digital Omnibus regulation that would repeal Regulation 2019/1150. The EU legislative tracker identifies procedure 2025/0360(COD) as ongoing as of this guide's review. A proposal is not the same as a regulation in force, and a platform should not remove current seller disclosures solely because the proposal exists. At the same time, it would be misleading to describe P2B as a static permanent framework without mentioning that the rulebook may change. Add a legal-monitoring owner and revisit the terms when the final text and application dates are known.

The proposed repeal also does not mean every ranking-transparency question disappears. The Digital Services Act and consumer rules have separate duties, and the Commission says its non-binding ranking guidance may remain relevant to other legislation. Do not substitute that observation for a future legal analysis: if the proposal changes or is enacted, map the final text against the platform's actual services and disclosure surfaces. For now, keep the Article 5 seller-terms control, DSA workflows and consumer display obligations separately documented so changes can be made precisely.

Before a new marketplace feature launches, verify the current Regulation text, the Commission ranking guidelines and the status of the Digital Omnibus proposal. This article addresses a Cyprus operator's P2B ranking disclosure, not how the marketplace itself can win search-engine positions. Ranking transparency is a platform governance and seller-information task. A company that inventories real factors, explains the important ones and reviews paid effects can adapt its documentation when the law changes without first discovering that the product and legal teams described different systems for years.

Basis and guidance: Regulation (EU) 2019/1150, Article 5 and relevant definitions; European Commission Notice 2020/C 424/01: ranking-transparency guidelines; Commission proposal COM(2025) 837, Digital Omnibus; EU legislative tracker: procedure 2025/0360(COD), ongoing; European Commission: platform-to-business trading practices

Primary sources and scope

Sources checked: October 8, 2026. This guide concerns the Republic of Cyprus. Examples are hypothetical, not client case studies. Check current official requirements before making a filing.

• Regulation (EU) 2019/1150, Article 5 and relevant definitions
• European Commission Notice 2020/C 424/01: ranking-transparency guidelines
• European Commission: platform-to-business trading practices
• European Commission Notice: guidance on the Unfair Commercial Practices Directive, ranking disclosures
• Commission proposal COM(2025) 837, Digital Omnibus
• EU legislative tracker: procedure 2025/0360(COD), ongoing