It's a very simple process whereby the institutions send us the wording of the request—because it's the request that has to be vexatious or made in bad faith—and then they have to give us the evidence or the arguments for why they believe it's a vexatious request. The requester has a chance to respond to the allegations and, based on those two submissions, we decide, based on the case law, whether or not the request itself is vexatious.
On April 18th, 2024. See this statement in context.