Procedural rights – Right to be heard
Article(s) involved (national, EU, or other):
Some SAs only allow submission on the “facts” from the complainant, but not on legal arguments.
The text should make clear that the right to be heard of the complainant includes the right to share submissions on the law and the facts in response to the controller’s submissions or the SAs’ (draft) opinion.
Concept 2 (applicable law and “leveling up”) should take care of the matter.