TL;DR
- The OECD has launched a public consultation on targeted amendments to the Model Reporting Rules for Digital Platforms, reflecting practical issues identified after implementation across multiple jurisdictions.
- The proposed changes focus on resolving practical implementation issues, including the scope of the rules, seller exclusions, duplicative reporting and intra-group arrangements, rather than redesigning the framework. Key areas include a higher monetary threshold (from EUR 2,000 to EUR 3,000) and the removal of the transaction-count test for low-value goods sellers, clearer definitions of “Platform” and “Platform Operator”, limitations to avoid duplicative reporting, and the introduction of a “Related Entity” concept to exclude certain intra-group arrangements.
- Companies operating digital platforms should actively assess these developments, as they signal ongoing refinement of global reporting obligations and may directly impact data collection, due diligence, and reporting processes.
A targeted update to the digital platform reporting framework
The OECD consultation document sets out proposed revisions to the Model Reporting Rules for Digital Platforms, a global reporting framework originally approved in 2020 and complemented in 2021 by an optional module that extends its scope to the sale of goods and the rental of means of transport. It requires platform operators to disclose sellers’ activities to tax authorities.
Following implementation in more than 30 jurisdictions, practical experience has revealed interpretative challenges and operational issues that require clarification or adjustment. The consultation aims to address these challenges through targeted amendments, rather than a full redesign, to improve the consistency and effectiveness of reporting outcomes.
Key proposed amendments
Rather than introducing new reporting concepts, the consultation focuses on practical implementation issues that have emerged since the rules were adopted, including uncertainty over which businesses fall within scope, when sellers can be excluded from reporting and how to avoid duplicate reporting.
Clearer definitions of “Platform” and “Platform Operator”
The OECD proposes refining the definitions of “Platform” and “Platform Operator” to address uncertainty about which businesses fall under the reporting rules, particularly when digital business models operate across multiple jurisdictions.
In practice, the clarifications confirm that a single platform may consist of several functionally integrated websites or applications, even where these are operated by different entities, and that an entity acting solely as a payment processor, with no independent knowledge of the underlying contract, services or consideration, falls outside the definition of platform operator.
The proposed clarifications are intended to reduce divergent interpretations and promote a more consistent application of the rules across jurisdictions.
Revised thresholds and “Excluded Sellers”
Under the current Optional Module, a seller dealing solely in goods is excluded from reporting only where the platform operator has facilitated fewer than 30 sales transactions for that seller and the total consideration does not exceed EUR 2,000 in the reportable period. The consultation proposes to simplify this test by removing the 30-transaction condition altogether and raising the monetary threshold from EUR 2,000 to EUR 3,000. The stated aim is to avoid reporting on private individuals who are unlikely to have a tax liability, such as people selling multiple low-value second-hand items. The practical effect is to widen the exclusion and reduce reporting, not to expand it.
It also provides further clarification of the categories of Excluded Sellers, including government entities, publicly traded companies and low-activity sellers, with the aim of focusing reporting on economically significant activity while reducing unnecessary compliance obligations.
Streamlined reporting and fewer duplicative obligations
A key objective of the consultation is to avoid situations where the same seller or transaction is reported more than once across different platforms or jurisdictions. Where the seller is itself a Reporting Platform Operator, the proposal would limit reporting to identifying information rather than requiring full transaction reporting. The proposal would limit reporting to identifying information and tax residency only, rather than requiring full transactional reporting. This approach addresses overlapping reporting chains that may arise across platforms and jurisdictions, supporting more efficient and consistent reporting outcomes.
A new “Related Entity” concept for intra-group arrangements
The proposed "Related Entity" concept would exclude certain intra-group platform arrangements from the reporting rules where no genuine third-party economic activity is involved. The proposal recognises that internal group structures may otherwise give rise to reporting obligations that do not reflect genuine third-party economic activity, reducing the proportionality and effectiveness of the framework.
For this purpose, two entities are related where one controls the other, or both are under common control, meaning direct or indirect ownership of more than 50% of the vote and value. A platform that facilitates activities exclusively for such related entities would itself qualify as an excluded platform operator.
Refined due diligence and reporting processes
At an operational level, the OECD also proposes refinements to due diligence and reporting processes, clarifying the extent to which platform operators may rely on internal records, publicly available information and confirmations from sellers. The requirement to obtain written confirmation from sellers that are themselves Reporting Platform Operators further reinforces the importance of accurate classification and robust data governance, both of which are becoming increasingly central to the operation of the rules.
Finally, the proposals on intermediary sellers, such as travel agencies, property managers or ride-hailing intermediaries that register as sellers on behalf of underlying providers, remain open: the relevant amendments are still shown in square brackets in the consultation document, and the OECD has specifically invited input on how to improve reporting outcomes in these cases.
Implications for platform operators
The consultation confirms that the Digital Platform Reporting Rules are entering a phase of operational refinement, with the focus shifting from framework design to the practical challenges of implementation across jurisdictions.
Platform operators should therefore view their existing compliance frameworks as dynamic rather than fixed. The proposed amendments warrant a reassessment of current approaches, particularly where interpretations of scope, seller classification, or reporting obligations have developed inconsistently across markets.
From an operational perspective, businesses may need to revisit data collection, due diligence, and governance processes to ensure they remain aligned with evolving requirements and documentation standards. The proposed introduction of the “Related Entity” concept may also require a review of group structures and internal platform arrangements, as some activities could fall outside the scope of reporting or become subject to different treatment.
In addition, the OECD’s focus on reducing duplicative reporting highlights the importance of identifying cross-platform and cross-jurisdictional reporting overlaps, which can otherwise lead to inefficiencies, inconsistent filings, and increased audit risk.
The consultation process itself also presents a valuable opportunity for businesses to provide practical feedback on areas where implementation challenges remain and to contribute to the development of the final rules.
What platform operators should do now
Against this backdrop, platform operators may wish to take a number of practical steps in the coming months:
- Re-examine scope and classification. Reasses show the entities in the group qualify as “Platform” and “Platform Operator” in light of the proposed clarified definitions, particularly for cross-border models where interpretations have differed.
- Map reporting overlaps. Identify where the same transactions may be reported across multiple platforms or jurisdictions, so that duplicative reporting can be reduced once the streamlining measures take effect.
- Review group structures. Assess whether internal, intra-group platform arrangements could fall outside scope under the proposed “Related Entity” concept, and how that would change current reporting practices.
- Strengthen due diligence and data governance. Check that data collection processes, seller categorisation and the handling of written confirmations from sellers can support the more precise documentation standards the rules are moving towards.
- Consider responding to the consultation. Where practical implementation issues persist, consider submitting comments before the 14 August 2026 deadline to help shape the final design.
Why this matters?
Although presented as targeted technical amendments, the proposed changes address issues that have a direct impact on day-to-day compliance. In particular, the revised definitions of “Platform” and “Platform Operator” may affect which businesses fall within the reporting rules, while the proposed changes on Excluded Sellers, duplicative reporting and the new “Related Entity” concept could reduce reporting obligations in situations where reporting currently provides limited value.
For platform operators, these changes may require reassessing existing classifications, reviewing intra-group platform arrangements and identifying areas where the same transactions are currently reported more than once. Addressing these issues now could help reduce unnecessary compliance costs and minimise the risk of inconsistent reporting across jurisdictions.
The consultation is also an opportunity for businesses to contribute practical implementation experience before the amendments are finalised. Providing feedback at this stage may help ensure that the final rules better reflect commercial reality and are easier to apply in practice.
Call for input
The OECD invites stakeholders to submit comments on the proposed amendments by 14 August 2026, with all submissions to be made public.
This is a key opportunity for businesses to raise operational concerns and help shape a more workable global reporting framework.
How can NOEMA help?
NOEMA can support platform operators in assessing the impact of the proposed amendments and understanding how they may affect their reporting obligations, due diligence processes, and seller classification frameworks.
Please get in touch if:
- you operate digital platforms across multiple jurisdictions subject to the Model Reporting Rules;
- you would like to assess whether your processes remain aligned with the proposed clarifications; or
- you are evaluating the impact of the new "Related Entity" concept on your platform arrangements.
