On 15 August 2026, Marin Popov submitted a new EU policy proposal: The Ranking Restriction Information Right (RRIR).
The proposal addresses a specific problem affecting websites, businesses, publishers and information providers operating in an increasingly automated digital environment.
Search engines and AI-powered search and answer services increasingly determine what information users see, find, retrieve and access. These systems can rank, filter, recommend and retrieve information automatically.
The problem is not that these systems make automated decisions.
The problem is that a website can experience a material restriction in visibility without being told that an automated restriction has occurred which directly affects business and revenue.
The problem
A website owner can see a substantial decline in impressions, clicks, traffic, rankings or discoverability in some tool, but those figures do not necessarily explain why the change happened.
It could be:
- an ordinary ranking change;
- a technical problem;
- a change in user behaviour;
- a change in search demand;
- an algorithmic change;
- or an automated system applying a restriction.
Search Console and similar tools can provide extensive information about the consequences of a visibility change. They do not necessarily tell the website owner that an automated restriction has been applied or provide a general category of reason.
This creates an information asymmetry.
The service can make an automated decision that materially affects the visibility of a website, while the affected owner may not even know that such a decision has been made.
Manual actions are not the same thing
There is an important distinction between a manual action and an automated restriction or demotion.
A manual action is an explicit enforcement measure identified by the service and communicated through an established notification mechanism.
An automated restriction can operate differently. A system can materially reduce the visibility of a website while the resulting effect appears only as a change in search performance.
The issue is therefore not a demand to reveal the underlying algorithm.
It is the absence of basic notice that a material automated restriction has occurred.
What does EU law already provide?
The EU already has several frameworks dealing with ranking transparency, algorithmic systems, platform accountability and digital markets.
P2B Regulation
The Platform-to-Business Regulation requires online search engines to describe the main parameters that are most significant in determining ranking and their relative importance.
It also makes clear that this does not require providers to disclose their algorithms or detailed ranking mechanisms.
This establishes an important principle:
Ranking transparency does not necessarily require algorithmic disclosure.
However, the regulation does not establish a general requirement to notify a website owner whenever an automated ranking system materially demotes or restricts that website’s visibility.
Digital Services Act
The Digital Services Act establishes broader transparency and accountability obligations for online platforms and very large online search engines.
It includes obligations concerning recommender systems, systemic risks and algorithmic systems, and gives the European Commission and Digital Services Coordinators powers to obtain information and, in appropriate circumstances, explanations concerning algorithmic systems.
But these mechanisms do not establish a general individual right for a website owner to be notified when an automated search system materially restricts that website’s visibility.
Digital Markets Act
The DMA adds another important dimension because search ranking and demotion can already be matters of EU regulatory scrutiny.
The Commission’s 2026 action concerning Google Search demonstrates that ranking conditions can be examined under EU competition and digital-market rules.
But the DMA does not currently establish the specific notification right proposed by RRIR.
The regulatory gap
Taken together, the existing frameworks establish several important principles:
- ranking is subject to transparency requirements;
- mechanisms affecting visibility can be subject to regulatory scrutiny;
- algorithmic systems can be examined by regulators;
- very large search engines can be required to explain aspects of their systems to regulators;
- transparency does not necessarily require disclosure of proprietary algorithms;
- search ranking can be subject to fairness and non-discrimination requirements.
What they do not clearly establish is a general right for a website owner to receive individual notification that an automated system has materially restricted or demoted the visibility of their website, together with a general explanation of the reason.
That is the specific transparency gap addressed by RRIR.
The Ranking Restriction Information Right (RRIR)
This proposal seeks to establish a narrow and proportionate transparency right for website owners affected by material automated visibility restrictions.
When an automated system materially restricts the visibility of a website in a search service, the affected website owner should be informed that such a restriction has occurred and provided with a general explanation of the category of reason for the restriction.
Where a service has identified a specific policy or compliance issue that is reasonably expected to result in a material automated restriction, the affected website owner should, where reasonably practicable, receive prior notice and a reasonable opportunity to address the identified issue before the restriction takes effect. Where a material restriction results from a dynamic or continuously operating automated evaluation and prior notice is not reasonably practicable, the notification should be provided after the restriction has taken effect.
The notification should identify the existence and general nature of the restriction without requiring the service provider to disclose the specific algorithmic mechanism that produced the decision.
The RRIR would not require disclosure of:
- proprietary algorithms;
- individual ranking signals;
- ranking thresholds or weighting;
- anti-spam or abuse-detection mechanisms;
- security-sensitive information; or
- information that could materially facilitate manipulation of the service.
The objective is therefore not algorithmic transparency in the sense of revealing how the system works. It is decision transparency: where an automated system materially restricts the visibility of a website, the affected owner should at least know that the restriction occurred and the general category of reason behind it.
The proposed requirement should apply only to material restrictions that have a significant and sustained effect on the visibility or discoverability of a website or information source, rather than to ordinary ranking fluctuations, routine algorithmic changes, or insignificant changes in visibility. Materiality should be assessed using objective and proportionate criteria established by the relevant regulatory framework.
Prior notification should not be required where providing advance notice would materially compromise the prevention or detection of fraud, spam, security threats, coordinated manipulation, or other forms of abuse. Where appropriate, the service should still be able to provide notification after the restriction has taken effect.
Why this matters
The proposal is deliberately narrow.
It is not intended to turn every ranking fluctuation into a regulatory event.
A website moving from position 7 to position 11 is not, by itself, the issue.
The proposal concerns material automated restrictions that have a significant and sustained effect on the visibility or discoverability of a website or information source. Ordinary ranking fluctuations, routine algorithmic changes and insignificant visibility changes would remain outside the proposed requirement.
The distinction matters because website owners currently have to infer a great deal from outcomes.
A notification that a material automated restriction occurred would provide information that traffic and ranking data alone cannot provide.
It could also allow the owner to investigate a genuine problem and take corrective action rather than spending significant time trying to determine whether an automated restriction exists at all.
Transparency without algorithm disclosure
This is perhaps the most important distinction in the proposal.
RRIR does not seek:
- source code;
- ranking formulas;
- individual ranking signals;
- thresholds;
- weighting;
- anti-spam detection methods;
- security-sensitive information.
A service would remain able to protect proprietary technology and mechanisms whose disclosure could facilitate manipulation, fraud or abuse.
The proposed right is therefore about decision transparency, not disclosure of how the entire system works.
Safeguards
The proposal includes explicit safeguards.
Notification would apply only to material restrictions.
It would not automatically apply to ordinary ranking fluctuations, minor visibility changes, temporary technical events or normal changes in search results.
Proprietary algorithms, source code, ranking formulas and commercially sensitive information would remain protected.
Anti-spam and abuse-detection mechanisms would also remain protected.
There would additionally be exceptions where advance notification could materially undermine the prevention or detection of fraud, spam, security attacks, coordinated manipulation or other abuse.
Where appropriate, however, a service could still notify the affected owner that a restriction occurred without revealing information that would compromise security or enforcement mechanisms.
What Marin Popov is asking the EU to examine
The proposal does not ask the EU simply to impose a predetermined technical solution.
It asks the relevant institutions to examine:
- whether the existing EU framework adequately addresses material automated restrictions of visibility;
- whether additional legislation, amendments, regulatory guidance or other measures are necessary;
- whether a notification-and-general-reason requirement should be introduced;
- what safeguards and exceptions would be appropriate.
The objective is not to interfere with legitimate ranking decisions or require disclosure of proprietary technology.
It is to establish a proportionate minimum level of transparency when automated systems materially affect the visibility of information.
Why Marin Popov is raising this
The reason is not only from a practical SEO and technology perspective but also mainly because such hidden decisions directly affect the business and life of people.
Website owners can experience substantial changes in digital visibility without receiving clear information about whether an automated restriction has occurred or, if one has occurred, the general category of reason behind it.
This is not a complaint about a particular website or a particular ranking decision.
It is a policy question about transparency and accountability in automated digital information systems.
The proposal has now been submitted
The full proposal has been submitted to:
- European Commission — DSA/VLOSE supervision
- European Parliament — Committee on Petitions (PETI)
- European Parliament — IMCO Committee
- Coimisiún na Meán — Ireland
- CNMC — Spain
The complete proposal is available as the formal PDF version.
The question is now on the table.