IEIM902235 - Extended Due Diligence for Existing Sellers

For any Sellers that were already registered on the Platform (pre-existing Sellers) on the date that the Platform Operator (PO) became a Reporting Platform Operator (RPO), the due diligence procedures can be completed by the end of the RPO’s second Reportable Period. This means that RPOs have an extra year to collect and verify the information from pre-existing Sellers, in recognition of the fact that new RPOs may need extra time to go back to pre-existing Sellers to get this information.

The date on which a person becomes an RPO will be either:

o   1 January 2024, when the regulations come into effect, or

o   any later date on which a person comes within the definition of being an RPO.

For example, a PO becomes tax resident in the UK on 1 July 2025 and therefore becomes an RPO in 2025 (first Reportable Period), it can complete due diligence procedures on its existing Sellers by 31 December 2026 (end of second Reportable Period). However, it must complete due diligence procedures by 31 December 2025 for any Sellers that were registered on or after 1 July 2025.

This extension of the due diligence deadline for existing Sellers is not mandatory. A RPO can choose to complete the due diligence procedures by the end of the first Reportable Period for some or all of its Sellers if it wants to.

For example, a PO becomes a new RPO on 1 January 2024. It carries out due diligence procedures on its new Sellers registered during 2024 and completes them by 31 December 2024. It decides to start the due diligence procedures on its existing Sellers but only manages to carry out due diligence on 60% of those as Reportable Sellers by the end of 2024. For the 2024 Reportable Period, the RPO will have to report the details of:

o  all new Reportable Sellers, and

o  the 60% of existing Sellers for whom due diligence has been completed

For the 2025 Reportable Period, the RPO will report the required information of:

o   all new Reportable Sellers registered in 2025,

o   the remaining 40% of existing Sellers for whom due diligence was not completed in 2024 but has been completed in 2025

o   the 60% of existing Sellers for whom due diligence had been completed in 2024 (provided they continue to be Reportable Sellers in 2025).

The reported details in respect of the 40% of existing Sellers will only be for the 2025 Reportable Period, not for the 2024 Reportable Period.

There may be circumstances where an existing Seller leaves a Platform before the end of the transitional relief period. This means that the RPO is unable able to carry out due diligence on that Seller.  

Where an existing Seller leaves a Platform during a Reportable Period, having carried out relevant activities, and the RPO is unable to complete Due Diligence, such as collecting the TIN, the RPO should report any information they have about the Seller to HMRC. The RPO should use ‘NOTIN’ in place of the missing TIN.