The European Commission accepted Temu's action plan for repairing its risk assessment on 26 October, closing the remedy stage of a case it opened in October 2024. Temu has four months to implement it, and the results go to an independent external audit.
Acceptance is not a finding that Temu has fixed anything. Under Article 75 of the Digital Services Act, a non-compliance decision obliges the platform to propose corrective measures; accepting the plan starts the clock on those measures. If they are not delivered, periodic penalty payments begin.
What Temu signed up to
Five commitments, all about how Temu studies its own marketplace rather than e-commerce as a category:
- A risk assessment tailored to its service, using reliable and up-to-date information about how the platform is designed, how it works and how people use it.
- Reliable metrics to test whether its mitigation measures actually reduce the spread of illegal goods, rather than assuming they do.
- An assessment of the limits of its proactive content moderation, and what those limits mean for recommended products.
- An analysis of how its recommender systems amplify illegal listings.
- A study of deliberate manipulation, including sellers exploiting Temu's own features to push questionable listings.
The fine behind all this was €200 million, issued on 28 May. The Commission's charge was specific: Temu's 2024 risk assessment leaned on general e-commerce information instead of evidence about its own service, and it badly underestimated how often EU shoppers would run into illegal items. A mystery-shopping exercise in the investigation found chargers failing basic safety tests and baby toys with chemicals above legal limits or parts that came off.
The board said it was thin
The European Board for Digital Services, which gathers the national regulators, gave its opinion on 24 September. It called the proposed changes partially adequate, and said the plan lacked enough detail to judge whether it actually addressed the infringement.
The Commission accepted it anyway, saying it had taken the board's opinion into consideration and clarified key requirements Temu must follow during implementation.
That is now a pattern. In July the Commission accepted X's action plan over a board opinion that judged it partially adequate and its audit measures insufficient.
Three clocks, and one that does not obviously add up
- Four months to implement the action plan.
- An interim risk assessment "that covers a six-month period, until 30 November 2026".
- An independent audit, with the report due to the Commission within four months after the measures are implemented, and a response to any auditor recommendation within one month after that.
The Commission's own wording puts a four-month implementation window beside a date five weeks away. Neither reading is spelled out in the published material: the assessment may be a retrospective six-month data window ending 30 November, or a deadline in its own right. Nothing on the record resolves it.
What is still unconfirmed
The action plan itself has not been published. The five bullets above are the Commission's summary, not Temu's text, so nobody outside the process can check how specific the commitments are. Temu has issued no statement of its own on the acceptance. And the Commission has not published the clarifications it added after the board's criticism, which is exactly where the missing detail would have gone.
What is verifiable is the sequence: a €200 million fine in May, a plan submitted in August, a lukewarm board opinion in September, and an acceptance in October that starts the clock. For scale, the Commission fined AliExpress €550 million in July on similar risk-assessment grounds, so Temu's penalty is no longer the largest DSA fine on the books.
This post will be updated when the interim assessment, the audit report or a Commission statement on implementation lands.
Sources
- Commission accepts Temu's action plan to remedy the breach of the DSA — European Commission, 26 October 2026
- Commission accepts Temu's corrective measures — European Commission, 26 October 2026 (board opinion of 24 September, audit timetable)
- Commission fines Temu €200 million for breaching the DSA — European Commission, 28 May 2026
- Ok Ue al piano della cinese Temu contro i prodotti illegali online — ANSA, 26 October 2026
- Bruselas acepta el plan de Temu para frenar la venta de productos ilegales — EFE, 26 October 2026
- Supervision of designated VLOPs and VLOSEs — European Commission enforcement register
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