On June 20, 2025, China issued State Council Order No. 810 (the Order), introducing new reporting obligations for online platform operators. ^[1] These requirements mandate platform operators to submit quarterly reports detailing the identity and income of merchants and individual workers operating on their platforms. To provide further clarity, the State Taxation Administration (STA) released two supplementary notices on June 26, 2025 (i.e., STA Announcement (2025) No. 15 and No. 16),^{[2] [3]} implementation specifics.

The Order is expected to impact e-commerce and other online platform operators, including both domestic and foreign entities. While businesses and individuals operating on these platforms are not directly subject to reporting obligation, they may be indirectly impacted as a result of having their identity and revenue information disclosed by the platforms.

This article explores the scope, reporting requirements, and implications of the Order (and the supplementary notices) for the affected businesses operating in or engaging with the Chinese market.

In-Scope Platform Operators

The Order applies to e-commerce platforms and businesses offering profit-driven services that facilitate online transactions, such as operating marketplaces, enabling transactions, or distributing information. Importantly, the Order extends its jurisdiction beyond domestic platforms to include foreign operators (e.g., platforms registered under overseas domains) if they provide profit-driven services within China.

Reporting Requirements

Key reporting obligations outlined in the Order and supplementary notices include:

• Platform Information: Operators must report details such as domain name, business nature, and operating entity within 30 days of commencing operations — or by July 30, 2025, for existing platforms.
• Merchant and Worker Information: Quarterly reports must include identity details, revenue amounts, and income nature for merchants and workers. The first report, covering Q3 2025, is due by October 31, 2025.
• Exempted Information: Revenue data for individual workers engaged in public convenience services (e.g., delivery, transportation, domestic work) eligible for tax exemptions or being nontaxable, or data already reported through tax withholding mechanisms, are excluded from reporting.
• Additional Tax-Related Data: Upon legitimate requests from tax authorities, platform operators may need to provide supplementary information, such as contracts, transaction records, financial accounts, and logistics details. Technical or access-related issues cannot be used as grounds for not sharing the information.

Tax Withholding Requirements

In addition to the information reporting obligations, the STA has introduced updates to clarify the Individual Income Tax (IIT) and Value-Added Tax (VAT) withholding responsibilities of platform operators through STA Announcement (2025) No. 16. Effective October 1, 2025, the key changes include:

• IIT Withholding: Platform operators remain responsible for withholding IIT on payments made to individual workers. However, the withholding calculation formula has been revised, which is expected to lower the withholding amount in most cases.
• VAT Withholding: Platform operators are required to withhold VAT on behalf of individual workers whose revenue exceed the taxable threshold. Recognising that platform operators may lack visibility into the total revenue earned by individuals operating across multiple platforms, the STA will actively notify platform operators of taxable individuals using the information collected.

A&M Insights and Recommendations for Businesses

China’s introduction of platform reporting obligations reflects the global trend toward enhanced tax transparency in the digital economy, as seen in the OECD’s Model Rules for Reporting by Platform Operators (MRR). By leveraging the data collected under the Order, Chinese tax authorities are poised to strengthen enforcement and improve tax collection from merchants and individuals earning income through online platforms.

In light of the additional compliance requirements, businesses must proactively assess and implement measures to address the implications of the Order. Below are key considerations:

For Platform Operators:

• Data Accessibility and Accuracy: Evaluate whether the platform has access to all required data and establish due diligence processes to ensure accuracy and completeness. Robust data governance framework is key.
• Record Maintenance: Maintain comprehensive tax-related transactional records beyond the reported data, as these may be requested during tax investigations.
• Contractual Updates: Revise terms and conditions with stakeholders as needed to reflect the new reporting obligations.
• Compliance With Data Protection Laws: Foreign platform operators may need to assess the interaction between the Order’s requirements and data protection regulations in their home jurisdictions (e.g., cross-border transfer of data). Seek legal advice if necessary.
• Tax Withholding Obligations: In addition to meeting the new information reporting requirements, platform operators should address the updated IIT and VAT withholding obligations to ensure full compliance.

For Merchants or Individual Workers:

• Tax Implications: Businesses and individuals eligible for tax exemptions are expected to remain unaffected. However, taxable individual workers may experience changes in the amount of taxes withheld by platform operators due to the revised IIT and VAT withholding mechanisms. Affected individuals should reassess their tax positions to ensure accurate withholding and compliance.
• Stricter Tax Enforcement: The reporting mechanism enhances tax authorities’ ability to identify under-reporting or non-reporting of income. Merchants and workers should maintain accurate transaction records and be prepared to justify potential discrepancies between platform-reported revenue and their own booked amounts in case of being queried by tax authorities (e.g., timing difference on income recognition).
• Operational Impact: Beyond tax compliance, the collected data may be shared with other regulatory bodies, such as the State Administration for Market Regulation, to address issues like fraudulent transactions (e.g., artificial traffic boosting or “brushing”). Merchants and workers should revisit promotional and sales strategies to ensure compliance.

How A&M Can Help

Navigating the additional reporting obligations introduced by the Order can be complex and challenging. At Alvarez & Marsal, our team is dedicated to assisting businesses in understanding and addressing these new requirements effectively.

For platform operators, we can provide tailored advice on the specific implications of the Order on your operations. We can also perform a comprehensive gap analysis to evaluate your existing systems and processes against the requirements outlined in the Order and assist with developing a robust data management framework, ensuring that you are fully prepared to comply.

For Chinese businesses operating on or foreign businesses selling to Chinese consumers via these platforms, the Order enhances tax authorities' visibility into online transactions, potentially leading to stricter enforcement. Businesses should consider preparing enhanced tax governance documentation in advance of any future tax authority engagement. We can also assist in identifying areas of potential noncompliance in your current business model and uncover opportunities for tax planning, while ensuring full compliance with applicable regulations.

If you would like to discuss these reporting obligations in more detail and how they may impact your business, please do not hesitate to reach out to us. Our team is here to help you navigate the changes with confidence.

[1] “Rules on Tax-Related Information Reporting by Online Platform Enterprises” (Chinese language), State Council Order No. 810, State Taxation Administration, June 20, 2025, https://fgk.chinatax.gov.cn/zcfgk/c100010/c5241238/content.html

[2] “Announcement on Matters Related to Tax-Related Information Reporting by Online Platform Enterprises” (Chinese language), STA Announcement (2025) No. 15, State Taxation Administration, June 26, 2025, https://fgk.chinatax.gov.cn/zcfgk/c100012/c5241477/content.html

[3] “Announcement on Handling Withholding Filings and Proxy Declarations for Platform-Based Individual Workers by Online Platform Enterprises” (Chinese language), STA Announcement (2025) No. 16, State Taxation Administration, June 26, 2025, https://fgk.chinatax.gov.cn/zcfgk/c100012/c5241472/content.html