Reddit's summary proceedings against the DPA over a penalty order and legal privilege dismissed

What it is about

Since March 2025 the DPA, as lead authority, has investigated whether Reddit lawfully makes users' public content available through its API to AI model developers. Because Reddit refused access to internal systems (Jira, Google Vault, SWAT Tables), on 26 January 2026 the DPA imposed an order subject to a penalty for breach of the duty to cooperate (Articles 31 and 58(1) GDPR with Articles 5:16, 5:17 and 5:20 of the General Administrative Law Act). Reddit sought, among other things, safeguards for legal privilege in summary proceedings. The court refused the relief because objections to the order and to the DPA's handling of privileged material can be reviewed by the administrative court. Reddit bears the costs.

What this means in practice

The DPA can demand access to your internal systems during an investigation and enforce it with an order subject to a penalty. If you dispute such an order and the DPA's handling of privileged material, the route is in principle objection and appeal before the administrative court; civil summary proceedings offer no way around that. Before an investigation starts, record which documents are privileged and how you flag them.

The GDPR articles concerned

• Article 31: Cooperation with the supervisory authority
• Article 58: Powers