IEIM904120 - Extended Reporting Timelines for new RPOs in respect of Existing Sellers

The model rules recognise that entities becoming Reporting Platform Operators (RPOs) for the first time may need time to fully operationalise the collection of information and documentation, and verification processes. For this reason, the rules grant transitional relief in respect of due diligence procedures to new RPOs for existing Sellers.

The transitional relief granted in respect of due diligence procedures means that a Seller that is identified as a Reportable Seller only in the second Reportable Period for the RPO would only be reportable in respect of the second Reportable Period with information to be reported by 31 January of the year following that second Reportable Period. A Seller should be considered to be ‘identified as a Reportable Seller’ when certain requirements are met (see 901620), and the due diligence has been completed. Where an RPO suspects that a Seller is likely to be a Reportable Seller but has not confirmed this by carrying out the necessary due diligence, the Seller is not ‘identified as a Reportable Seller’, and so the extended period can still apply.

For example, a Platform Operator becomes an RPO with existing Sellers on 1 January 2024, when the reporting rules come into effect. Some of the existing Sellers are identified as Reportable Sellers in the period 1 January 2024 to 31 December 2024. Information on those Sellers must be reported by 31 January 2025. Other existing sellers registered on the Platform prior to 1 January 2024 are not identified as being reportable until the period from 1 January 2025 to 31 December 2025. The information for those Sellers is to be reported by 31 January 2026. Information on new Reportable Sellers signing up to the Platform must always be reported by 31 January following the period in which they registered on the Platform.