Social media platforms assert great influence over data. The personal data of their users is used to fund the service through the sale of personalized advertisements. Though, more important for society, these platforms exert great power over the dissemination of available information. Social media platforms are increasingly used to communicate with other (likeminded) people. It is a platform where information and opinions are shared. In that sense, platforms form not only the guardians of users’ personal data, but they are also the gatekeepers of public information.

The access to social media platforms is traditionally governed by the platforms themselves. Platforms can dictate who gets access, which content can be shared, and what the grounds are for a (temporary) expulsion of the platform. Despite the discussion on whether social media platforms should be regulated as public utilities, or whether the operators must obey norms of fundamental rights as de facto public spheres, the direct influence of states on access to social media platforms has been limited. Recently, a (political) discussion has arisen in the Netherlands as to what extent administrative bodies should be able to impose administrative sanctions in online spaces. In the Netherlands, the access to physical places can be limited by administrative sanctions imposed by a municipality’s mayor. Could a mayor similarly impose an online restraining order, limiting a person’s access to a social media platform?

This article discusses online restraining orders as an administrative sanction. After a short introduction to the Dutch online restraining order, the article firstly discusses the traditional private governance framework to access a social media platform. In this first part, the normative online order set by platforms through their terms of service is discussed. After this contextualisation, the legal grounds to impose administrative sanctions under Dutch law are described, followed by a discussion on the online applicability of these competences, and a discussion on the transposability of physical legislation to online spaces. Lastly, the article concludes with a reflection on the future of online restraining orders.