The Digital Services Act gives a seller whose listing, account or content was restricted the right to take the dispute to a certified out-of-court body. Cotrugli fond — an association in Zagreb since 2007 — is applying to HAKOM, Croatia's Digital Services Coordinator, for certification with the scope application and enforcement of the terms of online marketplaces, in Croatian and English. The body's process is the NEO Chamber's published procedure; the technology is COTRUGLI Tech's. The body decides; the provider never does.
HAKOM's ordinance on the certification of bodies was in public consultation from 18 September to 19 October 2026; no certified body exists in Croatia yet; a decision follows within 60 days of a complete application once the ordinance is in force. Until HAKOM decides, nothing on this page is a certified body. The Fond's rules of procedure and schedule of costs are part of the application.
The platform keeps its own record of each decision (the listing, the terms version, the rule or model applied, the statement of reasons, the appeal, the implementation). The seller keeps a receipt made in the browser when the listing was published. Both books send only a 32-byte fingerprint to a neutral, sealed rail. Nobody hands a copy of the listing to a third party.
The NEO Chamber pairs the two books by the parties' own references, checks every receipt against the rail, asks for the originals it names by hash, and decides under its published rules of business: deadlines from a summons booked in the recipient's own book, a reasoned decision signed with the Chamber's key, and the platform's implementation recorded as a new record. A person decides; a machine checks what can be checked.
Under Article 21(5) the dispute is free of charge for the user. The platform pays per dispute and never more than the body's costs; the schedule of costs is published with the rules of procedure. An inadmissible dispute costs nothing; a platform that remedies at once pays a reduced fee.
Cotrugli fond decides; COTRUGLI Tech provides the technology and charges platforms by one public price list, with no contract that speaks of outcomes. Arbitrators have no connection to the provider. Every relationship is declared in the application and to HAKOM on every change.
Every record, receipt and decision carries a receipt that a public page recomputes in the browser — every hash and signature, two independent witnesses, nothing sent anywhere. A seller, a platform, HAKOM or a court can check a decision without trusting the body's word.
The body reports to HAKOM as the ordinance requires. In the public consultation (18 October 2026) we proposed that the report be machine-readable, that the completeness of a platform's documentation be part of the file, and that non-cooperation by a platform be recorded as such.
The platform's own system books the decision as a record in its own book; a fingerprint goes to the rail within a minute.
The seller files the dispute with the body and attaches the receipt its browser made at publication. Nothing of the listing's content goes anywhere it was not already.
The two books are paired by the parties' references; receipts are verified against the rail; originals are requested by hash within the deadline; the file lists what is missing.
A reasoned, signed decision under the published rules; both parties receive it with its receipt. Appeal by the rules; the ordinary court beyond.
The platform's implementation (or its refusal) is a new record in its own book — visible to the body and, in aggregate, to HAKOM.