Websites often give you a small task, such as spotting the traffic lights in a set of pictures. For a person it takes a second, but for a machine trying to log in thousands of times it is a brake. I propose the same idea for appealing against decisions made by public authorities. When someone files an unusually large number of appeals, each one would have to be confirmed in person with an official, on site or over a video call, explaining in their own words which decision they are appealing and why. For one genuine appeal that is a small effort; for a hundred copies it is enormous. Unlike an appeal fee, it does not put people with little money at a disadvantage, because the price is paid in time rather than money.
Making mass appeals scale badly
The idea is to add a small personal task to filing an appeal: easy to do once in a genuine matter but heavy to repeat dozens or hundreds of times. The goal is not to prevent appeals. The goal is to make mass appeals scale badly: the right to appeal remains, but automating appeals and copying them on an industrial scale becomes laborious.
In short: no fee for appealing, but an individual effort required from a human.
How the confirmation would work
The appellant specifies the matter to an official in their own words
The appeal is confirmed in person with an official, either on site or remotely. In their own words, the appellant states
- which decision they are appealing,
- what change they are demanding and
- why they believe that particular decision is wrong.
Every appeal needs its own confirmation. A single generic text cannot be copied into hundreds of cases, and strong electronic identification prevents anyone from gaming the system with different accounts.
An ordinary appellant faces no extra effort
The confirmation would only switch on when an unusually large number of appeals comes from the same person. An ordinary appellant who appeals once or twice in their own matter would never notice the system.
The cost is time, not money
The “price” is primarily time and personal participation. The advantage over an advance fee is that a person with little money is not inherently worse off: everyone has the same number of hours in a day, but not the same amount of money.
A remote option is essential
In-person visits alone would be a problem for, say, people with mobility impairments, people living in remote areas and people abroad. That is why an accessible remote option must be part of it.
Why this matters right now
The Finnish government is currently preparing measures against unfounded appeals. In September 2026 Minister of Justice Leena Meri said that an advance fee is being prepared for limited administrative court cases that do not concern the appellant’s own matter, along with a penalty fee for abuse of court proceedings (Verkkouutiset). Back in January, ministers launched a study that looks at, among other things, raising the fees of the administrative courts and the Supreme Administrative Court (Finnish Government). An appeals CAPTCHA is an alternative to precisely these money-based measures.
The problem is not new. As early as 2014, the news reported how one person had kept the city of Rovaniemi and the courts busy with more than 50 appeals, complaints and lawsuits (Verkkouutiset).
Novelty
I searched with terms such as (in Finnish) mass appeals, unfounded appeals, serial appellant, and vexatious litigant, proof of work spam, mass comments fake identities and in-person verification appeal.
Computational work against spam is an old idea
In 1993 Cynthia Dwork and Moni Naor proposed that an email sender should perform a small computational task that is cheap for one message but expensive for a million. Adam Back’s Hashcash implemented the same thing in 1997 (Wikipedia). An appeals CAPTCHA is the same principle, but instead of machine computation the cost is human time, which cannot be bought in bulk with a graphics card.
Restricting vexatious litigants today happens after the fact
In England and Wales a court can declare a person a vexatious litigant, after which they need a judge’s permission for every new proceeding (GOV.UK). That is a heavy, individually targeted and public label, given only after a long process. An appeals CAPTCHA would instead switch on automatically based on volume and would not require anyone to declare the appellant a nuisance.
Mass commenting is a threat that has already materialised
In 2017 the US Federal Communications Commission received more than 22 million comments on net neutrality, of which nearly 18 million were fake according to the New York Attorney General. One 19-year-old used software to submit 9.3 million comments under made-up names (New York Attorney General).
The difference: in-person confirmation triggered by volume, paid in time
I found no model in which an appeal must be confirmed with an official in one’s own words only once the same person’s number of appeals exceeds a threshold. The closest equivalents are paid for with money (court fees, the planned advance fee), with machine computation (Hashcash), or targeted at an individual through a heavy court decision (vexatious litigant orders). The novelty lies between these: a cost that triggers automatically, is the same for everyone and is hard to bypass with AI.
Theoretical value
Without the idea, AI makes appeals cheap and fees become common
In the next few years AI will make writing an individual-looking appeal almost free. A written requirement to “explain in your own words” will therefore no longer, on its own, separate a genuine appellant from a mass appellant, but a conversation with an official does so better. At the same time Finland is introducing advance fees and penalty fees. The baseline is thus a situation where mass appeals are fought with money. The idea’s value is how much more it stops and how much less it harms people with little money.
Fermi estimate: roughly $20 million – $1.3 billion a year
| Factor | Value | Source |
|---|---|---|
| Cases received by Finnish administrative courts (2024) | 19,215 | STT Info / Finnish courts |
| Cost per resolved case, Helsinki Administrative Court (2025) | €1,395 | Helsinki Administrative Court |
| Share of mass and serial appeals | 2–5% | own assumption |
| Idea’s additional effect on top of fees | 20–50% | own assumption |
| Cost of delayed projects in Finland | €1–10 million / year | own assumption |
| Multiplier for other wealthy democracies | 50–200 | own assumption |
| Euro to dollar | €1 ≈ $1.15 | own assumption |
- Court work: 19,215 × 2–5% ≈ 380–960 cases × €1,395 ≈ €0.5–1.3 million. 20–50% of that is €0.1–0.7 million.
- Project delays: €1–10 million × 20–50% ≈ €0.2–5 million.
- The cost of confirmations is small, because they only apply to those above the threshold: a few hundred half-hour meetings cost under €0.1 million.
- Finland in total: roughly €0.3–5.7 million, or about $0.35–6.5 million.
- Worldwide, with a multiplier of 50–200: roughly $20 million – $1.3 billion a year.
This excludes what the idea saves people with little money compared with fees, and the protection it gives authorities against AI-generated floods of appeals, which could be much larger than today’s.
What moves it most is how large the AI appeal flood becomes
This is an order-of-magnitude estimate, not a forecast. The biggest uncertainties are the cost of delays and whether mass appeals multiply with AI. If mass appeals stay at today’s level and fees work well, the idea’s added value stays at the low end of the range. If they grow like the FCC comment flood, money is no longer enough of a brake, and the value of a confirmation based on human time rises above the top of the range.