Quarterly BAS Due (July–September)
Form 1099-NEC & Contractor Payment Reporting Check
Why this matters.
The EU’s Digital Services Act (Regulation (EU) 2022/2065) has applied in full since 17 February 2024 and reaches well beyond businesses established in the EU. Any UK business offering “intermediary services” — hosting, marketplaces, app stores, social features, review sections, or online marketplaces — to users located in the EU or Northern Ireland is caught, regardless of where the business itself is based. Brexit does not provide an exemption: the DSA applies based on where a service’s users are, not where its operator is registered. Businesses in scope must appoint an EU legal representative if they have no EU establishment, publish clear terms and conditions on content moderation, provide a “notice and action” mechanism so users can flag illegal content or products, give a statement of reasons whenever they remove content or suspend an account, and — for online marketplaces — collect and display trader identity information (“Know Your Business Customer” checks) before letting a trader list goods.
Enforcement has ramped up steadily since 2024, with the European Commission and national Digital Services Coordinators opening investigations into platforms of all sizes, not just the largest “gatekeepers” already subject to separate Digital Markets Act duties. Penalties for non-compliance can reach 6% of global annual turnover, and micro and small businesses only benefit from limited, specific exemptions (mainly around systemic risk assessment obligations reserved for very large platforms) — the core transparency, notice-and-action, and terms-of-service duties still apply. UK online marketplaces, review platforms, forums, app stores, and any site hosting user-generated content or third-party listings that has any meaningful EU customer base should check their current terms, moderation processes, and marketplace onboarding against the DSA baseline requirements.
