Section 288

Regarding the timing of the application of the reporting platform operator rules and the transitional rules, the CRA indicated that:

• In the case of a seller (a “Legacy Seller”) who was already selling through the platform on the date its operator became a reporting platform operator (assumed to be January 1, 2024) the reporting platform operator would not need to complete its due diligence procedures in respect of the Legacy Seller in its first reportable period but would be required to do so by December 31 of the second reportable period. For example, it would be required to complete the due diligence procedures set out in ss. 283 to 287 in respect of a Legacy Seller by December 31, 2025, and if the Legacy Seller was identified as a reportable seller, this would result in the reporting platform operator being required to report the information set out in s. 292 in respect of the Legacy Seller to the Minister by January 31, 2026. If the due diligence procedures instead were completed during the first reportable period, then in this example, if the Legacy Seller was a reportable seller, the reporting platform operator would be required to report the s. 292 information by January 31, 2025.
• For sellers that registered on the platform after the operator became a reporting platform operator, the requirement to report the s. 292 information in respect of a seller identified as a reportable seller would be no later than January 31 of the year following the end of the reportable period. For instance, if the entity became a reporting platform operator on January 1, 2024, and a seller registered on the platform on March 31, 2024, the reporting platform operator would be required to complete the due diligence procedures by December 31, 2024, and complete the reporting by January 31, 2025.