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Ticketing, events and hospitality platforms

E-commerce and marketplaces

In short
Article 27 GDPR representative, plus an Article 13 DSA legal representative where the platform hosts third-party offers

Who has to appoint one

Ticketing and booking platforms established outside the Union serving customers in the EU. Where the platform intermediates between sellers and buyers it is a hosting service under the DSA with trader traceability duties, and where it sells directly it carries the consumer law obligations itself.

Thresholds and exemptions

No threshold for the data or consumer obligations. Micro and small enterprises get relief from some DSA platform duties but not from the legal representative.

What must appear on the label

Not physical. The representative in the privacy notice, the total price including all mandatory fees shown from the start, the identity of the actual seller where the platform is an intermediary, and the ranking parameters where offers are ordered.

Marketplace fields

Consumer authorities have acted repeatedly on drip pricing, false urgency, unverified review claims and hidden booking fees, and the CPC network coordinates cross-border cases against ticketing platforms specifically.

Documentation you must hold

Article 30 records covering customer, payment and attendance data, the Article 27 designation, DSA trader verification records, terms setting out cancellation and refund policies, and evidence supporting any review or availability claim displayed.

Standards and testing

Not applicable, though pricing and countdown mechanics are examined directly and screenshots taken by authorities become the evidence.

Language requirements

Prices, terms and cancellation information in the language of each market served.

When it applies

The representative before processing begins. The Omnibus price transparency and review verification rules have applied since May 2022, and the DSA since February 2024.

How long records are kept

Customer and attendance data only as long as necessary. Retaining ticket purchase histories indefinitely for marketing requires its own basis.

What happens if you do not comply

Consumer law penalties up to 4% of annual turnover in the member states concerned for widespread infringements, GDPR fines up to 4% of global turnover, and DSA penalties up to 6%. Ticketing has been one of the most targeted sectors for coordinated consumer enforcement.

Who enforces it

Consumer protection authorities through the CPC network, data protection authorities, and Digital Services Coordinators.

Where the boundary lies

The right of withdrawal does not apply to dated leisure services, which is why ticketing platforms rely on it, but that exemption does not extend to the fees, the transparency duties or the review verification obligations. Claiming reviews are verified without a verification process is itself an unfair practice.

Questions we are asked

Must we show fees upfront?
Yes. The total price including unavoidable fees must be shown from the outset, and adding mandatory charges at checkout is treated as drip pricing.
Is there a right of withdrawal for event tickets?
Not for services related to leisure activities on a specific date. The other consumer obligations still apply.
EU representative · from €290 / year

Who signs for you
EU representative Europe Services, SE — Na Čečeličce 425/4, Smíchov, 150 00 Praha 5, Czech Republic
UK representative REP27 LTD — Unit 82a James Carter Road, Mildenhall, Suffolk IP28 7DE, United Kingdom

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