IEIM902450 - Verification of Details of Pre-existing Sellers

Reporting Platform Operators (RPOs) are required to complete due diligence in relation to pre-existing Sellers who were already registered on the Platform before the reporting rules came into effect or before the Platform Operator became an RPO. Because these Sellers may have been registered on the Platform for some time prior to these rules coming into force, the level of verification possible may be more limited, as not all information will necessarily have been retained by the RPO. Accordingly RPOs may determine if information from pre-existing Sellers is reliable and verify it only against ‘electronically searchable records’ available to the RPO.

For example, suppose a pre-existing Seller was required to provide a copy of a photo ID on signing up to the Platform. The ID was checked at the time and it was confirmed this matched the details the Seller provided. The RPO recorded this fact on its computer system. However, the ID itself was not stored in an electronically searchable way (e.g. it was stored as a hard copy, or as a non-searchable image file). The RPO may check whether the information held about the Seller is reliable using the electronically searchable record that the ID matched the details provided. However, it would not have to check the information against the original copy of the photo ID, as this was not stored in an electronically certifiable format, and so it does not have to manually verify that the data matches.

This treatment applies only to pre-existing Sellers when the RPO first comes within scope of these rules and where the information already collected is reliable. If the RPO determines that a data item previously collected is no longer reliable or is incorrect, the RPO is required to collect and verify that item again using all available information.

When new Sellers join the Platform, or when updates are made to the information of pre-existing Sellers, due diligence must be carried out as normal.