Auditing Deliveroo and Wolt ranking disclosures under DSA Article 27: what restaurants can actually verify since 17 February 2024 — and what platforms still hide

This guide explains what restaurants can actually verify about Deliveroo and Wolt ranking disclosures under DSA Article 27 since 17 February 2024.

It outlines the limitations of platform transparency reports and merchant dashboards, and provides a quarterly audit checklist for restaurants to identify missing or inconsistent data.

How Ranking Disclosures Work

Under DSA Article 27, both Deliveroo and Wolt are required to disclose the main parameters that influence restaurant rankings on their platforms, but they are not obligated to reveal proprietary algorithmic weights such as the exact contribution of paid promotions or real-time demand throttling. This distinction allows platforms to maintain competitive advantages while still providing restaurants with enough transparency to assess fairness in visibility.

Deliveroo publishes a Transparency Report twice per year, which includes average commission rates and visibility into promotional spending. However, the report does not include real-time ranking factors or dynamic adjustments made during peak ordering periods. Restaurants should review these reports bi-annually and cross-reference them with their own performance data to identify discrepancies.

Wolt offers a Merchant Portal that provides performance metrics such as click-through rates and conversion rates, giving restaurants insight into how customers interact with their listings. Despite this, the underlying logic used to rank restaurants remains partially opaque, particularly regarding how factors like order volume, delivery time, and customer ratings are weighted in real time.

DSA Article 27 mandates that platforms disclose the main parameters affecting ranking, yet many platforms classify key elements as trade secrets, exempting them from full disclosure. For example, the specific weight assigned to paid promotions or the algorithm used for demand-based throttling is often withheld. Restaurants should verify whether disclosed parameters align with observed ranking changes and escalate inconsistencies to national DSA supervisors.

To audit platform disclosures effectively, restaurants should use the merchant dashboard and transparency report checklist on a quarterly basis. This includes checking for updates to disclosed parameters, comparing performance metrics against ranking positions, and documenting any unexplained shifts in visibility. If data is missing or inconsistent, restaurants should file a report with their national DSA supervisor immediately.

Evidence From Platform Reports

Starting 17 February 2024, restaurants seeking to verify Deliveroo and Wolt ranking disclosures under DSA Article 27 must rely solely on platform-provided transparency reports and merchant dashboards, as no alternative verification channels are offered. This limitation means restaurants cannot independently audit the underlying mechanics of how their listings are ranked, particularly regarding paid promotion weighting and real-time demand throttling, which remain undisclosed by both platforms.

Restaurants should check the latest Deliveroo Transparency Report for any stated percentage of visibility influenced by paid promotions, and note whether the report discloses the bidding mechanics behind that figure.

This omission prevents restaurants from understanding how their ad spend translates into visibility, making it difficult to optimize marketing budgets effectively. The report does confirm DSA compliance but stops short of providing itemized breakdowns of organic versus paid listing rankings.

Restaurants should review the Wolt Merchant Dashboard for any 'Visibility Score' or similar metric, and check whether the dashboard explains how factors like order volume and cancellation rate contribute to that score.

Without knowing how these variables interact, restaurants cannot make informed adjustments to improve their rankings, leaving them reliant on trial and error.

Restaurants should verify whether Deliveroo and Wolt explicitly reference DSA Article 27 compliance in their transparency reports and merchant dashboards, and whether those references include enough detail to support a ranking audit.

While they acknowledge the requirement to disclose ranking parameters under Article 27, they are not obligated to reveal proprietary algorithmic weights, creating a significant gap between regulatory compliance and practical transparency for merchants.

Restaurants should conduct quarterly audits of platform disclosures using the merchant dashboard and transparency report checklist, and escalate any discrepancies or missing information to national DSA supervisors.

This proactive approach ensures that restaurants maintain oversight of their platform visibility despite the inherent opacity of algorithmic ranking systems.

Options Compared: Audit Tools

Restaurants verifying Deliveroo and Wolt ranking disclosures under DSA Article 27 can choose from three distinct audit methods, each with trade-offs in cost, depth, and effort. This section compares the three primary approaches: manual dashboard review, third-party analytics tools, and formal legal requests under the DSA. Each method serves different needs depending on the restaurant’s compliance goals and resources.

Option A, manual dashboard review, involves logging into the merchant portal provided by Deliveroo or Wolt to inspect available ranking parameters and performance metrics. This approach is low-cost and accessible, making it suitable for restaurants conducting basic compliance checks. However, the data is often aggregated and lacks granular insight into real-time ranking adjustments or paid promotion weighting.

Option B leverages third-party analytics tools that integrate with platform APIs to track visibility trends over time. These tools offer moderate cost and partial data access, allowing restaurants to monitor shifts in ranking patterns. While useful for identifying long-term trends, they cannot access real-time signals such as demand throttling or proprietary algorithmic weights, limiting their effectiveness for detailed audits.

Option C involves submitting a formal legal request under the DSA to obtain more detailed disclosures from the platform. This method requires significant effort, including legal consultation and structured documentation, but offers the highest potential for comprehensive data access. It is recommended for restaurants conducting systematic audits or those suspecting non-compliance with transparency obligations.

Restaurants should select their audit method based on their compliance maturity and resource availability. For routine checks, manual dashboard review suffices. For deeper insights, third-party tools provide valuable trend analysis. For full transparency, legal requests under the DSA remain the most thorough option.

Costs And Compliance Burden

Auditing Deliveroo and Wolt ranking disclosures under DSA Article 27 carries measurable operational costs for small restaurant operators, particularly those managing multiple locations or operating on thin margins. The most accessible method—manually reviewing merchant dashboards and transparency reports—requires approximately two hours per month per location. At minimum wage rates across key European markets, this translates to roughly 40 in direct labor costs each month, or 480 annually per outlet. For a restaurant group with five locations, that figure rises to 2,400 per year, representing a non-trivial expense for businesses already navigating high commission fees and fluctuating order volumes.

Third-party audit tools offer automation but introduce recurring subscription costs ranging from 50 to 200 monthly, depending on the depth of features and the number of integrated locations. Basic tools may suffice for single-location operators, while enterprise-grade platforms supporting multi-location oversight can approach the upper end of the spectrum. These tools often promise real-time monitoring, anomaly detection, and report generation, but their value hinges on whether they can surface discrepancies in ranking disclosures that manual review might miss. Restaurants should weigh these costs against the potential revenue impact of unexplained ranking drops, which can significantly affect order volume and visibility on both platforms.

Independent legal action to compel disclosure or challenge platform practices under the DSA introduces additional financial risk. Formal legal requests require documented evidence and procedural rigor, and restaurants pursuing such avenues without in-house counsel may face legal fees exceeding 500, even for preliminary inquiries. While national DSA supervisors serve as the primary escalation path, the complexity of algorithmic transparency cases means that early-stage legal consultation is often necessary to frame complaints effectively. This cost barrier may deter smaller operators from seeking redress, despite having valid grounds under the regulation.

To manage these costs, restaurants should establish a quarterly audit schedule using a standardized checklist aligned with DSA Article 27 requirements. This checklist should include verification of disclosed ranking parameters, comparison of reported data against observed performance trends, and documentation of any inconsistencies or omissions. Any gaps identified during these audits should be escalated promptly to the relevant national supervisor, as delays may weaken the evidentiary basis for formal complaints. By treating compliance as an ongoing operational task rather than a one-time effort, restaurants can better protect their visibility and revenue on third-party platforms while fulfilling their rights under the DSA.

What Evidence Does Not Show

Despite the transparency reports and merchant dashboards made available after 17 February 2024, restaurants still cannot fully verify the fairness of Deliveroo and Wolt ranking systems because critical algorithmic behaviors remain undisclosed. This section alone identifies the critical gaps in platform disclosures that prevent full verification of ranking fairness. Neither platform explains how surge pricing or demand throttling influences restaurant visibility during peak ordering hours, leaving merchants unable to determine whether reduced exposure stems from their own performance or platform-driven suppression. Paid promotion weights are described only in qualitative terms, with no quantified breakdown of how much visibility boost a given ad spend actually delivers, making it impossible for restaurants to assess return on investment accurately. Real-time adjustments to rankings based on customer behavior, feedback loops, or dynamic demand signals are entirely absent from public disclosures, meaning restaurants cannot audit whether their position shifts are due to algorithmic bias or legitimate market forces. These omissions collectively undermine the ability of restaurants to hold platforms accountable under DSA Article 27, even when using the official verification tools provided.

Restaurants should treat undisclosed ranking factors as red flags during quarterly audits of their merchant dashboards and transparency reports, and flag any missing metrics when escalating concerns to national DSA supervisors.

Restaurants should cross-reference order volume trends with dashboard visibility scores and document any unexplained discrepancies for regulatory review, since platforms do not disclose real-time ranking adjustments.

Quarterly Audit

Restaurants can conduct a structured quarterly audit using this section's step-by-step template, which provides concrete checkpoints and outlines the consequences of non-compliance under DSA Article 27. This audit should be performed every three months using the merchant dashboard and transparency report checklist, with any missing or inconsistent data escalated immediately to national DSA supervisors.

Frequently Asked Questions

What specific tools can restaurants use to audit Deliveroo and Wolt ranking disclosures since 17 February 2024?

Restaurants can only audit Deliveroo and Wolt ranking disclosures through platform-provided transparency reports and merchant dashboards since 17 February 2024.

Is the weighting of paid promotions in ranking positions disclosed to restaurants?

Paid promotion weighting remains undisclosed to restaurants.

Can restaurants verify how paid promotions affect their ranking positions?

Platforms do not reveal how paid promotions affect ranking positions, leaving restaurants unable to verify this key signal.

Are real-time demand throttling adjustments included in transparency reports or dashboards?

Real-time demand throttling is hidden from restaurant audits.

How often should restaurants audit the ranking disclosures according to the reader rule?

Restaurants should audit disclosures quarterly and escalate missing data to national DSA supervisors.

What must restaurants use to perform quarterly checks under the reader rule?

The reader rule mandates quarterly checks using merchant dashboards and transparency report checklists, with escalation for inconsistencies.

Quick answers