IEIM902350 | Collection of Information where the Seller does not Co-operate

Reporting Platform Operators (RPOs) will need to determine how and at what point they collect information from Sellers, provided that the information is collected by the relevant deadline, usually 31 December of the Reportable Period. Where the RPO is already obliged to collect information under existing regulatory procedures e.g. under anti-money laundering legislation, the timing may be determined by that legislation.

Outside of this, RPOs may decide to collect the information as part of the onboarding process. If a Seller refuses to provide certain information, the RPO should encourage them to do so, explaining that the RPO is required by law to obtain the details. RPOs may take steps to enable their systems to prevent uncooperative Sellers from proceeding with onboarding, or to limit their access to the Platform until the process is complete and all necessary information has been provided.

Where an RPO does not collect the information during onboarding, or where the RPO has pre-existing Sellers using the Platform, it will need to ensure the information is collected subsequently, and by the relevant deadline. This may include going back to the Seller to ask for further information and could potentially include temporarily suspending access to the Platform until the Seller provides the information required.