Bounded instrument lane closed, 9 September 2026. Two directly associated official PDF originals acquired: the public version of the adopted decision with its commitment annex, and the Commission's monitoring-trustee notice. No live API, researcher application or third-party data was accessed. Root owns the announcements and current-status/fine review.
[Commission Decision C(2025) 3982 final, 18 June 2025](http[local research file] makes the annexed commitments binding under DSA Article 71. Its addressees are AliExpress International (Netherlands) B.V. and Alibaba.com Singapore E-commerce Private Limited (Articles 1–3, PDF 50–51 / decision pages 47–48). Do not replace the latter with the similarly named prospective successor mentioned in the procedural history.
The decision closes the covered proceedings except the specified illegal-content risk-assessment/mitigation grievance in case DSA.100117. The researcher-access section describes suspicions, not an adjudicated Article 40(12) infringement; the annex expressly preserves non-admission (PDF 44–47, recitals 156–164; PDF 54 / annex page 3). Binding acceptance is an actual intervention, but it is neither an infringement finding on access nor proof of fulfilled access.
The official 78-page copy states that confidential material was edited or replaced with summaries/omissions. Its metadata was generated in February 2026; that is not the decision date or receipt date. It is a public edited copy, not an unredacted instrument.
The operative instrument is Annex Section B.V, paragraphs 1–7, PDF 64–66 / annex pages 13–15. It concerns publicly accessible data under Article 40(12). It does not award vetted internal-data access under Article 40(4), trusted-flagger status, or access to a named research organisation.
AliExpress must maintain an exception to its general data-access restrictions for qualifying researchers, limited to systemic-risk research and applicable researcher terms. It must maintain a portal with dataset information, field explanations, tool instructions and an intake route; machine-readable access and reasonable downloads to researchers' own devices; near-real-time API access for readily available datasets; and gradual expansion informed by frequently requested datasets. The annex's examples include advertisements, stores/products and product/seller penalties. No such dataset was collected in this investigation.
| Who performs the step | Binding provision and precise timing | Limit |
|---|---|---|
| Trained AliExpress staff | B.V.3(i–ii): follow an internal SOP and assess eligibility within 15 business days. | Assessment is not automatic approval; the internal SOP was not acquired. |
| Researcher / data warehouse team | B.V.3(iii–iv): approved off-the-shelf access follows tool instructions; customised deployment is expected within 7 business days, with an express complex-development exception. | Do not turn the expectation into an unconditional seven-day deadline. |
| AliExpress QA team | B.V.6: monitor API stability, transmitted-data accuracy and median application processing time; conduct quarterly retrieval, reconciliation and API tests. | These are required checks, not acquired test results. |
| AliExpress → trustee | B.V.7: semiannual metrics/test reports, counts received/processed/approved/rejected, and researcher-feedback summaries. | No actual report, count or recipient list was acquired. |
The dedicated feedback email and the trustee's third-party query route are real stated channels. They are not an acquired adjudicatory appeal procedure for a denied research application. Do not import the decision's separate consumer/content-moderation complaint mechanism as that remedy.
The [official one-page trustee notice](http[local research file] states that the Commission approved Ankura Consulting (Europe), Limited on 23 September 2025. It identifies monitoring and reporting to the Commission as the role and permits third-party queries. This establishes a named appointment-approval step. It does not prove that a particular report was delivered, accepted or acted on, nor disclose fees paid.
The authority allocation is unusually explicit. AliExpress proposes the trustee/mandate and pays fees that must not depend on monitoring results; the Commission approves or rejects, may modify the mandate, and may issue orders/instructions to ensure compliance (C.1–5, PDF 74–75). Independence includes a 12-month restriction on related non-monitoring services before and after, and a limit on prior consecutive monitoring service; ordinary Article 37 audit service is distinguished. No separate independence assessment or executed remuneration terms were acquired.
The trustee may recommend compliance measures and must promptly report reasonably concluded failure, without waiting for scheduled reports. It may not make technical/product/business decisions or exercise the Commission's investigative powers (C.12–13, PDF 76–77). Advance notice of potentially adverse material changes expressly does not require trustee approval, and experimental/beta/testing changes are excepted (C.17). Necessary-information access is bounded by its mandate and coordination with the auditor; the Commission resolves disagreement over the information process within 14 calendar days (C.12(iii), C.15–16). Confidentiality, specific permitted audit-document sharing, and restrictions on public statements apply (C.13–14). A privately paid monitor is not thereby a private regulator with platform-management powers.
The Effective Date is receipt of the decision, not automatically 18 June (definitions, PDF 55; Section E, PDF 78). No receipt record was acquired. The initial implementation period runs to 30 September 2025, with best-efforts compliance during rollout; thereafter obligations apply in full (C.10, PDF 75–76). The first trustee report was due within two months after that cycle; subsequent reports cover cycles ending 30 September 2026 and 30 September 2027 (C.12(iv), PDF 76; recitals 167–171, PDF 48). Their existence or delivery is not established here.
The substantive measures run five years from receipt. The trustee mandate runs through its final report on the cycle ending September 2027. C.7–8 allow replacement/discharge and handover; they do not expressly create automatic renewal beyond that reporting period. Section D allows the Commission to waive, modify or substitute commitments if DSA conditions no longer justify undiminished continuation. This is not treated as an exercised extension or a general renewal right.
Two source-text issues remain visible. C.9, PDF 75, prints “31 November 2027,” an impossible date. Recital 167 instead says 30 November, and C.12(iv) expresses the deadline as two months after 30 September. This was visually verified and is not silently normalized. Separately, recital 174 (PDF 49) says internal QA continues through the five-year term; Section D (PDF 78) says all monitoring/reporting obligations lapse when the commitments expire at final-report submission, while other substantive measures continue for five years. The decision's stated continuing-QA expectation and the annex's broader lapse wording should both be retained; this lane does not resolve their legal interpretation.
That issue does not imply all independent oversight ends in 2027: the decision separately points to continuing DSA risk assessment and Article 37 independent audit obligations (recital 174). The specific trustee, internal QA and general DSA audit are different mechanisms.
Recital 9 (PDF 6) describes pre-decision changes to AliExpress' transparency tools, including research-access options and downloads. This is an official historical implementation account, not an audit that every annex obligation was satisfied. The trustee approval provides a further concrete implementation step. No actual application decision, data delivery, QA report, trustee report or Commission acceptance of performance was acquired.
For breach, recital 180 expressly preserves reopening under Article 71(2). The decision does not impose an access-related monetary fine. Root's separate current-status reading identifies the 20 July 2026 EUR 550 million announcement as concerning illegal-product risk assessment/mitigation outside the settled grievances; it must not be used as proof of researcher-access breach or trustee failure. That later announcement, its full infringement decision, payment and appeal status are outside this worker's two-original acquisition scope.
The highest-value next record is the first trustee report due in November 2025, together with the underlying B.V.7 researcher-access statistics/feedback and the Commission's response. These would test whether the process opened access, denied it and why, or triggered correction. Known holders are AliExpress, Ankura and the Commission. The internal researcher-assessment SOP and executed trustee mandate/fees are also specific gaps. No missing record is assumed nonexistent and no holder was contacted.
Originals: ali-decision.pdf (78 pages, scoped read) and ali-trustee.pdf (one page, full text and visual read). Decision text scope: PDF 1–6, 44–51, 53–56, 64–66, 74–78. Decision images actually viewed: 65, 66, 74, 75, 77, 78. Other page-level keyword hits were only used to select these sections; a full-document extraction is not a full read. Both original GETs returned PDFs after the reader failed with Unicode decoding errors. No additional acquisition or retry followed. Exact metadata, hashes and ancestry are in ali-captures.json; no graph or packaging edits.