Artifact GuideEU

DSA marketplace trader traceability

A grounded guide for online platforms that let consumers in the EU conclude distance contracts with traders.

Use it to structure seller onboarding, reliability checks, product listing fields, consumer disclosures, retention rules, and workflow evidence under DSA Articles 30-32.

Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Sections
6

Structured answer sets in this page tree.

Primary sources
3

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

DSA trader traceability is a marketplace onboarding and listing-control obligation, not a generic trust-and-safety note. Article 30 applies to providers of online platforms that allow consumers to conclude distance contracts with traders for products or services offered to consumers located in the Union. The practical test is whether the marketplace can collect the required trader data before access, assess whether it is reliable and complete, display the consumer-facing fields at the point where the product or service appears, store the file securely, and suspend marketplace access when required information is missing or not corrected.

Section 1

Scope the marketplace and the trader relationship

Start with the service model. The DSA marketplace traceability duties sit in the section for providers of online platforms that allow consumers to conclude distance contracts with traders. A marketplace should document which storefronts, apps, booking flows, promoted listings, brand-sponsored offers, and third-party seller journeys let EU consumers contract with a trader.

Do not treat every platform feature as a trader-traceability feature. Community posts, search results, advertising services, hosting infrastructure, and content moderation workflows can trigger other DSA duties, but this guide concerns trader onboarding and product or service offers made through an online marketplace.

  • Record the consumer journey where the contract is concluded or promoted, including country availability and whether the recipient is located in the Union.
  • Identify whether the counterparty is a trader and whether the offer is for products, services, or promoted messages about products or services.
  • Separate marketplace traceability from VLOP, advertising, recommender, notice-and-action, and transparency-reporting obligations unless the same product also triggers them.
  • Check whether the provider qualifies as a micro or small enterprise exclusion for this DSA section; designated very large online platforms do not use that exclusion.
Section 2

Collect the Article 30 trader file before marketplace access

A covered marketplace should not allow a trader to use the platform to promote messages on products or services, or to offer products or services to EU consumers, until it has obtained the Article 30 trader information where applicable. The onboarding flow should block publication until all required fields are either completed or marked not applicable with a reason.

The required file is concrete: trader name, address, telephone number and email; an identity document copy or electronic identification; payment account details; trade-register or equivalent public-register details when the trader is registered; and a trader self-certification to offer only products or services that comply with applicable Union law.

  • Make every required field a structured onboarding control rather than a free-text note in an internal ticket.
  • Store proof of the source used for each field: trader submission, official register lookup, payment account document, eID result, or company certificate.
  • Use a separate completeness status for points (a) to (e) so operations can see exactly why a trader is blocked.
  • For traders already using the marketplace on 17 February 2024, keep an evidence trail of the 12-month collection outreach, missing items, deadline handling, and any suspension for non-response.
Section 3

Assess reliability, completeness, and correction triggers

Article 30 does not make the marketplace a guarantor of every trader statement. It requires best efforts to assess whether the required trader information is reliable and complete before access, using freely accessible official databases or interfaces made available by a Member State or the Union, or supporting documents from reliable sources requested from the trader.

Build a correction workflow for stale, inconsistent, or suspicious records. When the marketplace has sufficient indications or reason to believe a required item is inaccurate, incomplete, or not up to date, it should ask the trader to remedy the issue without delay or within the applicable legal period. If the trader does not correct or complete the information, the marketplace should suspend the service for offers to EU consumers until the request is fully complied with.

  • Record which official database, register, VAT or trade-register interface, eID check, payment account document, or company certificate was used.
  • Keep the verification result separate from the raw document so privacy controls can limit access to identification and payment records.
  • Use mismatch reasons such as name mismatch, missing register number, expired document, unreachable contact channel, payment account mismatch, or missing self-certification.
  • Preserve trader complaint routes when access is refused or suspended, because Article 30 links refusal and suspension decisions to complaint mechanisms.
Section 4

Design listings so traders can provide product and service information

Article 31 turns traceability into product design. A marketplace interface should allow traders to provide pre-contractual information, compliance information, and product safety information required by applicable Union law. It should also let traders identify the product or service clearly, show signs identifying the trader such as a trademark, symbol or logo, and provide applicable labelling and marking information.

Before allowing the offer, the marketplace should make best efforts to assess whether the trader has provided the Article 31 information. After publication, it should make reasonable efforts to randomly check official, freely accessible, machine-readable databases or interfaces to see whether offered products or services have been identified as illegal.

  • Add required listing fields for product or service identification, economic-operator contact fields where applicable, trader marks, and applicable safety or compliance labels.
  • Block publication where required product, service, compliance, or product-safety fields are incomplete.
  • Keep a random-check register showing the sampled listings, official database used, result, reviewer, and follow-up action.
  • Do not describe random checks as a general monitoring duty; Article 31 frames them as reasonable efforts against official machine-readable sources.
Section 5

Display consumer-facing trader information and handle illegal offers

Article 30 requires the marketplace to make selected trader information available to recipients in a clear, easily accessible, and comprehensible way. At minimum, the product or service interface should expose the trader name and contact details, trade-register information where applicable, and the trader self-certification commitment that only compliant products or services will be offered.

If the marketplace becomes aware that an illegal product or service has been offered to EU consumers through its service, Article 32 adds a consumer information workflow. Where contact details are available, consumers who purchased the illegal product or service in the six months before the marketplace became aware should be told that the product or service is illegal, the identity of the trader, and relevant means of redress. Where contact details are not available for all affected consumers, the marketplace should make that information publicly available and easily accessible on its interface.

  • Place the consumer-facing trader fields on or next to the product or service page, not only in a help center or post-purchase email.
  • Maintain a publication check proving that Article 30(1)(a), (d), and (e) fields display clearly for each live trader listing.
  • Create an illegal-offer incident record with the discovery source, affected listings, affected consumers with contact details, public notice content, redress information, and removal or suspension action.
  • Keep support scripts aligned with the consumer notice so users receive the same trader identity and redress information across channels.
Section 6

Keep secure records and workflow evidence

Trader traceability records contain identification, contact, payment, register, and self-certification data. Article 30 requires secure storage during the contractual relationship and for six months after it ends, followed by deletion. Disclosure to third parties should occur only where required under applicable law, including DSA information orders or orders from competent authorities or the Commission.

A useful evidence file should prove both the legal duty and the operational control. It should show the trader's lifecycle from onboarding through verification, live display, random product or service checks, correction requests, suspension or reinstatement, consumer notices for illegal offers, and deletion after the retention period.

What information must a DSA-covered marketplace collect from traders?

Article 30 requires, where applicable, trader contact details, identity or eID evidence, payment account details, trade-register details, and a self-certification that the trader will offer only products or services complying with applicable Union law.

Does the marketplace have to guarantee that trader information is correct?

No. The DSA requires best efforts to assess reliability and completeness using official online databases or reliable supporting documents. Article 30 states that traders remain liable for the accuracy of the information they provide.

How long should Article 30 trader information be kept?

The DSA requires secure storage for the contractual relationship and six months after it ends, followed by deletion, unless another applicable law requires a different preservation step.

  • Keep a trader traceability register with status, required fields, verification method, verification date, reviewer, source used, and open defects.
  • Store raw identity and payment evidence with restricted access, audit logging, retention labels, and deletion triggers tied to the contractual end date.
  • Keep screenshots or rendered-page checks proving consumer-facing trader disclosures were visible on product or service pages.
  • Maintain separate logs for correction requests, trader complaints, suspensions, random database checks, illegal-offer notices, and retention or deletion actions.
Primary sources

References and citations

digital-strategy.ec.europa.eu
Referenced sections
  • Commission-hosted Board page confirms that DSA Articles 30-32 are handled as consumer and online marketplace issues involving consumer protection, customs, market surveillance, and other authorities.
"Articles 30-32 of the DSA"
digital-strategy.ec.europa.eu
Referenced sections
  • Commission overview states that marketplaces must make reasonable efforts to perform random checks or adopt traceability technologies.
"reasonable efforts to perform random checks"
eur-lex.europa.eu
Referenced sections
  • Article 30(5)-(6) sets secure storage, six-month post-relationship retention, deletion, and limited disclosure rules.
"They shall subsequently delete the information."
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