IEIM902410 - Verifying Using Information Available to the Platform

Reporting Platform Operators (RPOs) will collect a variety of information depending on their own policies as well as other obligations to which they are subject, such as Anti-Money Laundering (AML) requirements. As well as being required to collect certain information under these regulations, RPOs may also collect data items such as an email address as part of their onboarding, a phone number and bank account information for the payment of Consideration.

RPOs must use all available records and consider the information collected as a whole to determine if it is reliable and correct.

For the purposes of carrying out due diligence, information is available to the RPO if it is in the power, possession or control of the RPO, or if the RPO otherwise has access to the information, whether directly (e.g. through a computer system), or indirectly, (e.g. because it is able to request the information from another RPO, another group company, or a third party). See 902210 for further information on reliance on, and access to information from, third parties.

Specifically, with respect to verification of a TIN, the RPO should also make use of publicly available records and information. This could include using any publicly available automatic checking tools or apps that enable the format of a TIN to be checked if there is any doubt about the reliability of a Seller’s TIN. RPOs should confirm that a TIN provided matches the correct format where applicable. In the UK, NINOs are made up of two letters, followed by six numbers and then a final letter. There are certain restrictions on which characters can appear in which place. More information on this can be found at gov.uk here: https://www.gov.uk/hmrc-internal-manuals/national-insurance-manual/nim39110

There is no expectation that the RPO further verifies the reliability of the TIN to ensure that it is correct by collecting additional information or documents that are not already available to the RPO in its own records or that of third party service providers, unless the RPO has doubts as to the reliability of the TIN, for example ,if the TIN provided does not meet formatting requirements, is clearly false (e.g. AA 11 11 11 A), or if the tax authorities inform the RPO that a previously reported TIN is incorrect.

Where an RPO relies on a third party to carry out due diligence, the information available to the RPO must still be taken into account in determining reliability, and therefore should still be considered ‘available’. Similarly, if multiple RPOs are involved in carrying out due diligence on a Seller, they cannot separate the information held by one RPO from the information held by the other RPO in such a way that it would limit the ‘available’ information for the purposes of determining reliability.

Where an RPO collects multiple TINs, for example if it also collects VAT registration numbers, it does not have to verify these for the purposes of the reporting rules.