Exploratory study of consumer issues in online peer-to-peer platform markets : final report.
Date: 2019-08-02
Institutions: Directorate-General for Justice and Consumers
Subjects: EU Member State, business model, cloud computing, collaborative economy, consumer policy, consumer protection, data protection, financial transaction, goods and services, hiring, liability, national law, sale, used goods

Exploratory study of consumer 
issues in online peer-to-peer 
platform markets  

Final Report 

Authors  
VVA:  Pierre  Hausemer,  Julia  Rzepecka,  Marius  Dragulin,  Simone  Vitiello,  Lison  Rabuel,  Madalina 
Nunu, Adriana Rodriguez Diaz 
Milieu: Emma Psaila, Sara Fiorentini 
GfK: Sara Gysen, Tim Meeusen, Simon Quaschning, Allison Dunne 
Vadim Grinevich with Franz Huber and Linda Baines 

Contract 2015 86 02; Project 2017.4058 
May 2017 

Justice and 
Consumers 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION  

EUROPEAN COMMISSION 

Produced by Consumers, Health, Agriculture and Food Executive Agency (Chafea) on behalf of 

Directorate-General for Justice and Consumers 
Directorate E — Consumers 
Unit E.1 — Consumer policy 

Contact: Antonia Fokkema 

E-mail:  JUST-CONSULT-E1@ec.europa.eu 

European Commission 
B-1049 Brussels 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Exploratory study of 
consumer issues in online 
peer-to-peer platform 
markets 

Final Report 

2017 

Directorate-General for Justice and Consumers 
EU Consumer Programme   

Exploratory study of consumer issues in online peer-to-peer platform markets – 
Final Report 

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DS-01-17-528-EN-N - ISBN 978-92-79-69183-6 - doi:10.2838/779064

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Exploratory study of consumer issues in online peer-to-peer platform markets – 
Final Report 

TABLE OF CONTENTS 

3 

ABSTRACT ................................................................................................... 10 
EXECUTIVE SUMMARY ................................................................................... 12 
INTRODUCTION ..................................................................................... 20 
1 
1.1  Peer to Peer online platform markets: a consumer policy perspective .... 20 
1.2  Aims and objectives of this study ..................................................... 22 
1.3  The scope of the study ................................................................... 23 
2  METHODOLOGICAL APPROACH ................................................................ 25 
2.1  Task 1 - Desk research and literature review ..................................... 25 
2.2  Task 2 – Survey ............................................................................ 26 
2.3  Task 3 – Focus groups .................................................................... 28 
2.4  Task 4 – Case studies ..................................................................... 28 
2.5  Task 5 – Legal Analysis .................................................................. 29 
2.6  Task 6 – Workshops ....................................................................... 30 
2.7  Data availability and data gaps ........................................................ 31 
STATE OF PLAY OF ONLINE P2P PLATFORM MARKETS ................................. 32 
3.1  Size of P2P platforms ..................................................................... 32 
3.2  Overview of services offered by P2P platforms ................................... 32 
3.3  Peer usage of P2P platforms ............................................................ 39 
3.4  Economic significance of P2P online platform markets ......................... 43 
3.4.1  Methodology ...................................................................... 43 
3.4.2  Peer consumer expenditure ................................................. 44 
3.4.3  Peer provider revenue ......................................................... 49 
3.4.4  Estimate of platform and other non-peer revenue ................... 51 
BUSINESS MODELS OF P2P PLATFORMS ................................................... 54 
4.1  Monetisation models of P2P platforms ............................................... 54 
4.2  Core features in P2P business models ............................................... 55 
4.3  Model 1: Hosting of Listings ............................................................ 58 
4.4  Model 2: Actively managed transactions............................................ 58 
4.5  Model 3: Platform governed peer transactions ................................... 59 
4.6  The business model typology and the case study platforms .................. 59 
PEER EXPERIENCE, PERCEPTIONS, EXPECTATIONS AND PROBLEMS IN P2P 
MARKETS ............................................................................................. 66 
5.1  Levels of peer satisfaction ............................................................... 66 
5.2  Peer consumer problems and personal detriment ............................... 69 
5.2.1  Problems experienced by peer consumers .............................. 69 
5.2.2  Comparing  problems  experienced  using  P2P  platforms 

5 

4 

versus using conventional businesses .................................... 72 
5.2.3  Consumer detriment ........................................................... 73 
5.3  Problems of peer providers ............................................................. 74 
CLARITY AND TRANSPARENCY OF INFORMATION ON P2P PLATFORMS ........... 76 
6.1  Peer perceptions of clarity and transparency on P2P platforms ............. 76 
6.2  Platform  practices  and  approaches  to  clarity  and  transparency  of 

information ................................................................................... 78 
6.2.1  The contractual nature of the transaction ............................... 78 
6.2.2  Pricing .............................................................................. 80 
6.2.3  Terms and conditions .......................................................... 81 
6.2.4  Data and data protection ..................................................... 83 
TRUST BUILDING & VERIFICATION OF INFORMATION ON P2P PLATFORMS .... 86 
7.1  Peer perceptions of peer reviews, ratings and reputation systems ......... 87 
7.2  Platform  practices  regarding  peer  review,  ratings  and  reputation 

systems ....................................................................................... 89 
7.3  Platform practices regarding pre-screening and identity verification ...... 91 
7.4  Cross-platform portability of reputations and identity verification .......... 94 
ACCESS TO COMPLAINTS, REDRESS AND INSURANCE ON P2P PLATFORMS.... 96 
8.1  Peer experiences in addressing problems on P2P platforms .................. 96 

6 

7 

8 

6 

Exploratory study of consumer issues in online peer-to-peer platform markets –  
Final Report 

9 

8.2  Platform practices regarding complaints, redress and insurance ............ 97 
8.2.1  Complaints and redress ....................................................... 97 
8.2.2  Access to insurance ............................................................ 99 
REGULATORY ELEMENTS IN P2P PLATFORM PRACTICE ............................... 101 
9.1  The nature of the transaction ......................................................... 101 
9.1.1  EU legal framework ........................................................... 101 
9.1.2  National regulatory approach .............................................. 101 

9.2  Overview  of  the  national  legislation  applicable  in  the  context  of 

online peer-to peer platforms ......................................................... 102 
Legislation applicable to C2C transactions ............................. 102 
9.2.1 
Legislation  applicable  to  online  platforms  facilitating  P2P 
9.2.2 
transactions ..................................................................... 104 

9.2.3  Specific  issues  in  platform-peer transactions as identified  in 

the national context ........................................................... 105 
9.3  Practical application and current enforcement challenges .................... 107 
9.3.1  Challenges  to  enforcement  of  the  national  horizontal 

legislation applicable to C2C transactions .............................. 107 

9.3.2  Challenges  to  enforcement  of  the  national  sector-specific 

legislation applicable to C2C transactions .............................. 108 

10  POTENTIAL  FUTURE  MARKET  DEVELOPMENTS  IN  ONLINE  P2P  PLATFORM 

C. 

MARKETS ............................................................................................ 110 
11  OVERVIEW OF KEY CONCLUSIONS .......................................................... 113 
KEY FINDINGS AND CONCLUSIONS ......................................................... 113 
Economic analysis of P2P markets ................................................... 113 
A. 
Peer experiences in online P2P markets ........................................... 117 
B. 
Clarity and transparency of information on P2P platforms ................... 119 
C. 
Trust  building  and  verification  of  identity  information  on  P2P 
D. 
platforms..................................................................................... 120 
Access to complaints, redress and insurance ..................................... 122 
E. 
Regulatory elements in practice ...................................................... 122 
F. 
CONSUMER ISSUES & POLICY OPTIONS ................................................... 125 
Transparency and clarity ................................................................ 126 
A. 
Consumer  trust  and  accuracy  of  user  generated  information  on  the 
B. 
platform ...................................................................................... 128 
Platform  responsibility  and  liability  for  the  performance  of  the  P2P 
transaction .................................................................................. 129 
Access to redress .......................................................................... 130 
Data (re)use and data protection .................................................... 130 
Further research ........................................................................... 131 
12  ANNEXES ............................................................................................. 133 
12.1  Annex 1: Task 1 Report ................................................................. 133 
12.2  Annex 2: Task 2 Report ................................................................. 133 
12.3  Annex 3: Task 3 Report ................................................................. 133 
12.4  Annex 4: Task 4 report .................................................................. 133 
12.5  Annex 5: Task 5 Report ................................................................. 133 
12.6  Annex 6: List of platforms considered in Task 1 ................................ 133 
12.7  References .................................................................................. 133 
12.7.1  Academic literature ........................................................... 133 
12.7.2  Reports ............................................................................ 135 
12.7.3  Legal ............................................................................... 137 
12.7.4  Online articles ................................................................... 138 
12.7.5  Websites .......................................................................... 140 

D. 
E. 
F. 

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Exploratory study of consumer issues in online peer-to-peer platform markets –  
Final Report 

TABLES  

Table 1: Number of P2P platforms per country and sector included in Task 1 .......... 26 
Table 2: Sample size in Task 2 survey ............................................................... 27 
Table 3: Task 3 criteria for focus group recruitment ............................................. 28 
Table 4: Overview of P2P platform services ........................................................ 34 
Table 5: Usage of online P2P platforms .............................................................. 39 
Table 6: Engagement with online P2P platforms in 10 MS ..................................... 41 
Table 7: Differences in use of online P2P platforms, by sector, 10 MS .................... 41 
Table  8:  Frequency  of  active  use  of  online  P2P  platforms  –  Sector  breakdown  (Peer 
consumers) ............................................................................................. 42 
Table  9:  Frequency  of  active  use  of  online  P2P  platforms  –  Sector  breakdown  (Peer 
Providers) ............................................................................................... 42 
Table 10: Use of single or multiple platforms (consumers and providers) ................ 43 
Table 11: Total estimated annual peer consumer spending in EU28 MS .................. 46 
Table 12: Overview of common features in P2P business models ........................... 56 
Table 13: Typology of business models .............................................................. 57 
Table 14 : Mapping of case study platforms onto the business model typology ........ 61 
Table 15: Satisfaction with overall experience using P2P platforms ........................ 66 
Table 16: Satisfaction with overall experience using P2P platforms  – Peer Consumers
 ............................................................................................................. 67 
Table 17: Satisfaction with overall experience using P2P platforms – Peer providers . 67 
Table 18: Satisfaction with experience using P2P platforms compared to conventional 
business – Peer consumers ....................................................................... 68 
Table 19: Satisfaction with experience using P2P platforms compared to conventional 
business, sector breakdown ....................................................................... 68 
Table 20: Problems experienced – Frequency breakdown ..................................... 69 
Table 21: Problems experienced – Sector breakdown category .............................. 71 
Table  22:  Experienced  similar  problems  when  using  conventional  business  –  Sector 
breakdown .............................................................................................. 72 
Table  23:  Saving  money  using  a  P2P  platform  in  comparison  with  conventional 
business (Peer consumers) ........................................................................ 72 
Table  24:  Average  level  of  personal  detriment  experienced  as  a  result  of  problems 
experienced by peer consumers on P2P platforms ......................................... 73 
Table  25:  Average  personal  detriment  level  -  Comparison  between  online  P2P 
platforms and Market Monitoring 2015, ....................................................... 74 
Table 26: Incidence of problems experienced by providers with other peers ............ 74 
Table 27: Problem types experienced by providers .............................................. 75 
Table  28:  Proportion  indicating  having  experienced  a  payment  issue  or  no  show  / 
cancellation issue - Size & (Re)Sale vs collaborative breakdown ..................... 75 
Table 29: Importance of clarity and transparency about… - Peer consumers ........... 77 
Table 30: Importance of clarity and transparency about… - Peer Providers .............. 77 
Table 31: Knowledge of rights for peer consumers and peer providers ................... 78 
Table  32:  Different  platform  approaches  regarding  transparency  about  private  and 
commercial peer providers ........................................................................ 79 
Table 33: Information about pricing .................................................................. 80 
Table 34 : Platform data protection and data sharing policies ................................ 84 
Table 35 : Use of review/rating systems by peer consumers and providers before and 
after a transaction (consumers and providers) ............................................. 87 
Table 36: Peer consumer views regarding the user review/rating systems .............. 88 
Table 37: Peer review and reputation systems .................................................... 90 
Table 38: Pre-screening of peers and identity verification ..................................... 93 
Table 39: Consumer actions when problems occur .............................................. 96 
Table 40: Actions the platform has taken in response to the problem ..................... 96 
Table  41:  Satisfaction  with  how  the  other  peer  dealt  with  your  complaint  (Peer 
consumers) ............................................................................................. 97 
Table 42 : Access to complaints and informal redress by the platform .................... 98 
Table 43: Availability of insurance across 10 platforms ........................................ 99 

8 

 
 
Exploratory study of consumer issues in online peer-to-peer platform markets –  
Final Report 

FIGURES 

Figure 1 : Different layers of rule-making on online P2P platforms ......................... 21 
Figure 2: Services provided by P2P platforms ..................................................... 33 
Figure 3: Prevalence of different services in selected P2P platforms ....................... 36 
Figure 4 : Pre-transaction services, divided by P2P market ................................... 38 
Figure 5: Availability of mobile apps on P2P platforms, per sector of activity ........... 39 
Figure 6: Number of active P2P market participants in the total population (aged 16-
74), EU-28 extrapolated from EU-10 ........................................................... 40 
Figure  7:  Mean  and  median  P2P  consumer  expenditure  in  the  last  12  months,  per 
sector in the 10 MS under study, in EUR...................................................... 45 
Figure 8: Total estimated yearly spending by peer consumers on P2P platforms, by EU 
Member State. ........................................................................................ 46 
Figure 9: Total estimated annual peer consumer spending in P2P online markets, per 
sector, EU-28 .......................................................................................... 48 
Figure 10: Total estimated annual peer consumer spending in P2P markets, per sector 
(without (Re)sale of goods), EU-28 ............................................................ 48 
Figure 11: Mean and median annual P2P provider revenue, per sector, EUR ............ 49 
Figure  12:  Total  estimated  annual  peer  provider  revenue  in  the  P2P  online  markets, 
per sector, EU-28 .................................................................................... 50 
Figure  13:  Total  estimated  annual  peer  provider  revenue  in  P2P  markets,  per  sector 
(without (Re)sale of goods), EU-28 ............................................................ 51 
Figure 14: Comparison between revenues and expenditure (EUR Bn) ..................... 52 

9 

 
 
 
Exploratory study of consumer issues in online peer-to-peer platform markets –  
Final Report 

ABSTRACT  

This  study  explores  consumer  issues  in  five  online  peer  to  peer  platform  markets: 
(Re)sale  of  Goods;  Sharing/renting  of  goods,  Sharing/renting  accommodation; 
Sharing/hiring rides; and Odd jobs.  

The  study  estimates  that  191m  citizens  across  the  EU-28  spend  EUR  27.9  billion  per 
year on online P2P platforms. Of this total, an estimated EUR 10.61 billion consists of 
platform revenues and revenues of third parties. 

The  study  defines  three  main  peer-to-peer  platform  business  models:  (a)  hosting  of 
listings where platforms do not get involved in the peer to peer transaction (b) active 
management  of  transactions  where  platforms  foster  trust  among  peers  to  facilitate  a 
larger number of transactions and (c) platform governed peer transactions where the 
platform  sets  one  or  more  contractual  terms  for  the  peer-to-peer  transaction  and 
exercises control over the performance of the transaction. 

The  study  identifies  five  key  consumer  issues  that  emerge  from  this  new  kind  of 
economy: (1) transparency and clarity regarding the nature of transactions concluded 
through  online  P2P  platforms,  applicable  consumer  rights  and  obligations,  the 
applicable  legal  framework  and  its  enforcement;  (2)  reliability  of  peer  review  and 
rating  systems  and  accuracy  of  identity  information  provided  on  the  platform;  (3) 
discrepancy  between  exclusion  of  platform  responsibility  and  liability  for  the 
performance  of  online  P2P  transactions  and  platform  practices;  (4)  access  to  redress 
for peer consumers and peer providers; and (5) data use and data protection issues. 

10 

 
 
 
 
 
Exploratory study of consumer issues in online peer-to-peer platform markets – 
Final Report 

EXECUTIVE SUMMARY 

The  exploratory  study  on  consumer  issues  in  peer-to-peer  (P2P)  online  platform 
markets  investigates  five  P2P  markets  and  identifies  the  main  issues  for  peer 
consumers and peer providers from the perspective of consumer policy.  

The study focuses on P2P online platforms for a) (Re) Selling or Buying of Goods - like 
eBay;  b)  Sharing  or  Renting  of  Goods  –  like  Peerby;  c)  Sharing  or  Renting 
Accommodation – like Airbnb; d) Sharing or Hiring rides – like BlaBlaCar or Uber; and 
e) Hiring people to do Odd Jobs – like Yoopies. With the exception of the (re) sale of
goods sector, these sectors are part of what the European Commission has defined as
the  "collaborative  economy",  or  what  is  more  generally  referred  to  as  the  "sharing
economy".

The study comprises six tasks: a review of existing literature and 485 platforms across 
the  EU  and  Norway;  a  consumer  survey  and  focus  groups  covering  10  EU  Member 
States; 10 case studies of selected platforms, a Legal Analysis covering 28 EU Member 
States and two workshops with stakeholders.  

Economic analysis of P2P markets 

It is estimated that 191m citizens across the EU-28 have actively engaged in peer to 
peer  markets  between  May  2015  and  May  2016,  concluding  at  least  one  transaction 
involving  payment.  Total  peer  expenditure  over  this  period  in  the  EU  across  the  five 
sectors considered  is estimated at EUR 27.9 billion per year; total peer revenues are 
estimated  at  EUR  17.29  billion.  The  difference  of  EUR  10.61  billion  includes  platform 
revenues and revenues of third parties providing services via platforms, e.g. payment 
services, background and ID checks, insurance services.  

in 

the  (re)sale  or 

In the sharing/hiring rides sector peer providers reported revenues add up to 81% of 
renting/sharing  of  goods,  accommodation 
expenditure; 
sharing/renting  and  odd  jobs  sectors,  this  is  only  about  60  to  65%.  Expenditure  and 
revenue  on  both  collaborative  and  (re)sale  of  goods  platforms  are  driven  by  a  small 
share  of  peer  consumers  and  peer  providers.  More  than  half  of  the  revenue  and 
expenditure is generated by 10% of peers. This indicates the presence of 'very active 
private' consumers and providers, and/or of commercial and professional sellers in P2P 
markets.  

Among  the  485  platform  websites  screened,  20  platforms,  or  4%  of  them,  are  very 
large and have more than 100.000 unique visitors per day; a large majority (81%) are 
small  or  medium-sized  (below  10,000  daily  visitors).  Almost  80%  of  sharing/hiring 
rides  and  almost  70%  odd  jobs  platforms  are  small,  with  less  than  500  daily  unique 
visitors. The platforms provide a wide range of services to peers which they monetise 
through  selling  advertising  or  promotion  of  listings  on  the  platform,  data  use  and 
reuse for their own or third party (marketing) purposes, and by charging fees. These 
include  transaction  fees,  charged  to  peers  on  each  transaction  concluded  on  the 
platform;  subscription  fees,  charged  to  peers  on  a  periodical  basis  for  access  to 
platform  services;  add-on  services  fees  for  optional  services;  other  fees  such  as 
cancellation fees, hotline fees, B2B fees etc. 

Combining  findings  on  monetisation  strategies  and  platform  services  with  the  case 
studies, three main platform business models are identified:  

1. Hosting  of  listings:  this  model  is  characterised  by  passive  matching  of  peer
demand and peer supply: publishing listings and enabling contact and feedback
between  peers  by  publishing  information  from  peers.  These  platforms  earn
revenues  mostly  by  offering  featured  listing  options,  adding  photos  to  the
listings,  etc.  The  key  feature  of  this  model  is  that  platforms  do  not  become
involved in the peer to peer transaction.

11 

Exploratory study of consumer issues in online peer-to-peer platform markets –  
Final Report 

2.  Actively  managed  peer  transactions:  this  model  is  characterised  by  the 
active  facilitation  and  management  of  the  matching  of  demand  and  supply. 
These  platforms  create  value  by  fostering  trust  among  peers  and  actively 
managing  the  matching,  so  as  to  facilitate  a  larger  number  of  transactions. 
These  platforms  manage  trust-building  and  advanced  matching  tools,  and 
charge transaction fees or subscription fees. They may also charge for add-on 
services  like  insurance  or  premium  listings.  The  key  feature  of  this  model  is 
that the platform influences the peer to peer transaction but does not control it.  

3.  Platform  governed  peer  transactions:  this  model,  which  concerns  mainly 
the larger platforms, is characterised by setting one or more of the contractual 
terms  of  the  peer  to  peer  transaction,  and  exercising  control  over  its 
performance. Setting contractual terms may include rules for P2P interactions, 
rules  and  fees  for  cancellations,  and  rules  for  refunds;  (optional)  automated 
price  setting  or  maximum  prices.  Platforms  in  this  model  manage  payments  - 
receiving  and  holding  payments  of  peer  consumers  -,  monitor  the  success  of 
the P2P transaction before paying out to peer providers, and frequently retain 
fees  in  case  of  cancellations.  They  further  actively  intervene  in  case  of  a 
complaint, resolve disputes and award refunds and they may include insurance 
against damages as part of the transaction fee. Most of these platforms charge 
transaction  fees  and  re-use  peer  data.  The  key  feature  of  this  model  is  that 
these  platforms  restrict  the  ability  of  peers  to  decide  contract  terms  between 
them,  and  give  the  impression  (explicitly  or  implicitly)  that  they  assume 
(partial) responsibility for the performance of the transaction.  

The  three  business  models  are  to  some  extent  “incremental”:  platforms  that  actively 
manage  peer transactions  also provide  hosting  and  matching  services,  and  platforms 
that  govern  peer  transactions  offer  most  of  the  services  of  the  other  two.  Platform 
business models evolve over time from the simpler to the more complex models and 
offer a wider range of services as their user base grows. 

Peer experiences in online P2P markets 

More than three quarters of internet users in the ten countries surveyed for this study 
have over the past 12 months concluded one or more transactions on a P2P platform - 
73% had used platforms for the Sale and Resale of Goods; 8% platforms for Odd Jobs, 
12% platforms for Sharing/Renting of Goods, 14% Accommodation Renting/Sharing to 
15% of the  online population using Ride Sharing/Hiring platforms. About half of both 
peer  providers  and  consumers  (54%)  use  these  P2P  platforms  monthly  or  weekly.  A 
substantial proportion of peer providers in the accommodation sector report that they 
rent  out  accommodation  on  a  regular  basis,  15.9%  once  a  week  and  20.6 %  once  a 
month. Most peers (77% of peer providers and 83% of peer consumers) are satisfied 
or very satisfied and want to use the platform again in the future. 

Peer  consumers  report  frequent  problems  with  transactions  on  P2P  platforms.  More 
than half (55%) have experienced at least one problem over the past year. The most 
frequent problems relate to the poor quality of goods or services, or to the goods and 
services not being as described. Problems with the quality of products/services appear 
to be almost twice as frequent in P2P markets (29%) as in online purchases in general 
(15%). However, peer consumers rate the personal detriment they experienced as low 
to  medium.  Furthermore,  focus  group  research  indicates  that  peer  consumers  may 
accept a higher level of risk and problems on P2P platforms as "part of the game" - in 
exchange  for  the  opportunity  to  save  money,  and  because  most  transactions  are 
relatively low value.  

More  problems  are  reported  on  collaborative  platforms  than  on  (Re)sale  of  goods 
platforms. Problems on accommodation platforms were less likely to get resolved than 
problems  on  other  collaborative  platforms.  Peer  providers  report  fewer  problems 
(14%)  than  peer  consumers;  most  relate  to  cancellations  (over  40%)  and  various 
payment issues (47.5%).  

12 

 
 
 
Exploratory study of consumer issues in online peer-to-peer platform markets –  
Final Report 

Consumer issues and policy options 

The emergence and development of online peer to peer markets has both positive and 
negative  effects  on  consumers.  On  the  one  hand,  online  platforms  offer  efficient 
matching of supply and demand, reduce transaction costs, and facilitate monetising of 
under-utilised  resources  and  new  employment  opportunities.  On  the  other  hand, 
significant  consumer  issues  were  identified  regarding  a)  transparency  and  clarity  of 
the  legal  nature  of  transactions  on  P2P  platforms  and  the  applicable  rights  and 
responsibilities,  b)  the  reliability  of  peer  review  and  rating  systems  and  accuracy  of 
identity  information;  c)  the  discrepancy  between  exclusion  of  platform  responsibility 
and liability for the performance of online P2P transactions and platform practices; d) 
access  to  redress  for  peer  consumers  and  peer  providers;  and  e)  data  use  and  data 
protection issues. 

Some  of  the  consumer  issues  that  arise  on  online  P2P  platforms  could  be  solved 
through  self-regulation  by  the  P2P  platforms,  notably  through  greater  transparency 
about  rights,  obligations  and  responsibilities.  However,  self-regulatory  approaches  of 
platforms  are  often  voluntary,  they  do  not  address  all  consumer  issues  and  they 
mainly  rely  on  incentives  rather  than  systematic  enforcement  or  sanctions.  Because 
addressing  the  consumer  issues  above  may  not  directly  promote  transactions  on  the 
platform - which is the main source of revenue of the major platforms - self-regulatory 
measures alone might not be sufficient.  

1. Platform transparency  

One of the main issues concerning the relationship between platforms and their users 
relates  to  the  lack  of  transparency  in  online  P2P  platform  rules  and  practices.  The 
survey and focus groups have shown that most peer consumers (60%) are not aware 
or  uncertain  of  their  rights  and  responsibilities  in  P2P  transactions  or  who  to  turn  to 
when  something  goes  wrong.  About  40%  of  peer  providers  say  they  do  not  know  or 
are  not  sure  about  their  rights  and  responsibilities,  and  about  30%  think  they  know 
more or less. 

At  the  same  time  about  85%  of  peer  consumers  find  it  important  or  very  important 
that P2P platforms are clear and transparent about who is responsible when something 
goes wrong, and their rights in case of a problem with the price or quality of a product 
or service. Peer providers attach similar importance to clarity and transparency about 
regulations and responsibilities when something goes wrong. 

To  determine  rights  and  responsibilities,  distinguishing  between  those  acting  in  a 
commercial/professional  capacity  and  individuals  acting  in  a  private  capacity  is 
essential. The Legal Analysis finds that the ‘continuity’ and the ‘professional nature’ of 
the  activity  are  the  two  main  elements  Member  States  use  to  assess,  on  a  case-by-
case basis, whether an individual is acting in a private capacity or as a trader. Sector-
specific  thresholds  and/or  tax  thresholds  differ  from  sector  to  sector,  as  well  as 
between  countries,  or  even  regions  and  cities,  and  are  not  necessarily  relevant  to 
distinguish  consumers  from  traders  for  consumer  law  purposes.  Potential  policy 
options  include  monitoring  legal  initiatives  adopted  at  Member  State  level  and 
assessing  their  effectiveness;  and  a  statute  of  ‘prosumers’  or  'micro  entrepreneurs'  - 
as used in France -  as a new type of economic operator. 

Irrespective  of  the  actual  definition  of  traders and  consumers,  the  case  studies  show 
that  in  practice  some  platforms  do  not  allow  or  make  it  difficult  for  commercial  peer 
providers  to  operate  alongside  private  peers;  others  allow  both  types  of  peers  and 
require peer providers to clarify whether they are acting in a private capacity or not – 
while  others  do  not  require  providers  to  give  any  such  information.  This  may  not 
generate  any  substantial  problems  in  the  case  of  platforms  serving  smaller  local 
communities,  and/or  where  transaction  amounts  are  low.  But  on  some  of  the  larger 
platforms which give peer providers opportunities to make significant profit, this lack 
of  transparency  raises  concern:  not  identifying  those who are  acting  as professionals 
or  traders  implies  they  may  act  as  'hidden  traders'.  Platforms  possess  the  data  to 

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assess  relevant  indicators,  such  as  frequency  of  transactions  and  number  of  listings, 
and they can monitor the validity of the information given by peer providers. 

Further  transparency  is  also  necessary  in  pricing  practices.  The  search  results  on 
many  platforms  do  not  give  the  total  price;  platform  fees  which  range  from  10%  to 
25%  are  often  added only  at  the booking  stage.  Among the  10 case  study  platforms 
only  the  French  language  version  of  BlaBlaCar  displays  prices  in  search  results  that 
include the transaction fee.  

Transparency issues could be addressed by requiring platforms to clearly indicate the 
(self-declared) status of the peer provider, and that consumer law applies exclusively 
in transactions with traders. Platforms should ensure that peer consumers receive pre-
contractual information when they engage in transactions with commercial providers. 
In addition, platforms could make their Terms and Conditions more user-friendly and 
ensure that key information about rights and responsibilities is presented more clearly 
and  at  the  point  of  the  transaction  when  it  is  most  useful.  Platforms  could  inform 
providers  where  they  can  find  information  about  applicable  national  or  local 
registration,  licensing  or  authorisation  requirements.  Finally,  awareness  raising 
campaigns  could  boost  online  P2P  platform  user  knowledge  about  their  rights  and 
responsibilities  -    making  appropriate  funding  available,  for  example  to  trusted 
stakeholders such as consumer associations.  

2.  Reliability  of  peer  review  and  rating  systems  and  accuracy  of  identity 
information provided on the platform  

 “Trust  building  tools”  are  often  presented  by  platforms  as  their  main  instrument  for 
protecting  peer  consumers  and  peer  providers  against  fraud  and  other  risks  and  for 
ensuring  the  quality  of  goods  and  services  and  reliability  of  providers.  While 
conventional  businesses  generate  consumer 
through  compliance  with 
governmental  regulations,  platforms  generate  trust  by  managing  peer  review,  rating 
and  reputation  systems  and  identity  verification.  The  results  of  the  screening  of  485 
platforms,  the  user  survey  and  focus  groups,  and  the  case  studies,  indicate  that  the 
core  trust  building  tools,  peer  review  and  rating  systems  as  operated  by  most 
platforms  and  their  identity  verification  practices,  are  neither  fully  reliable  nor 
transparent. Their effectiveness is therefore subject to serious doubt.  

trust 

Online P2P platform users do not use peer reviews and rating systems systematically 
and  they  do  not  always  trust  them.  In  addition,  most  platforms  do  not  appear  to 
monitor  systematically  whether  reviews  or  ratings  are  generated  by  actual  and 
genuine  users.  Moreover,  many  platforms  do  not  offer  these  core  trust  building 
services. While about half (52%) of the 485 platforms screened for this study offer a 
peer review and rating system, almost half of them do not offer such a service. User 
data checks and identity verification services were identified on only 25% of platforms. 
Among  the  case  study  platforms,  nine  out  of  ten  manage  peer  rating  systems,  and 
eight out of ten peer review systems.  

The  survey  findings  show  that  neither  peer  consumers  nor  peer  providers  use  peer 
reviews  or  ratings  systematically.  Only  about  40%  of  peer  consumers  and  peer 
providers use reviews regularly, and more consult reviews before the transaction than 
write  them  afterwards.  This  indicates  that  reviews  are  unlikely  to  reflect  the 
experience  of  all  platform  users,  but  those  of  a  smaller  number  of  more  involved 
peers.  In  particular,  as  only  20%  of  peers  said  they  left  a  negative  review  or  rating 
after encountering a problem with a transaction, there are indications that rating and 
review systems may be biased.  

The  survey  shows  that  although  most  peer  consumers  evaluate  user  review  systems 
positively,  three  quarters  of  peer  consumers  have  at  least  some  reservations  about 
their reliability and their ability to generate trust, provide adequate information, safety 
and  protection.  The  focus  group  research  indicates  that,  instead  of  relying  only  on 
peer reviews and ratings, peers evaluate the overall reliability of a platform through a 
combination of elements. 

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The  case  studies  raise  further  questions  about  the  transparency,  reliability  and 
neutrality  of  the  management  of  peer  review  and  rating  systems.  Most  platforms  do 
not inform users whether positive or negative reviews or ratings influence the search 
results or access to the platform; and those who do so, do not explain clearly how this 
is done. All platforms reserve the right to delete reviews if they do not respect certain 
standards.  While  some  platforms  systematically  check  reviews  before  publication,  or 
monitor  them  afterwards,  on  other  platforms  it  is  not  clear  whether  the  platform 
monitors reviews or relies on peers to signal suspicious content. None give information 
to  users  about  the  representativeness  and  reliability  of  user  reviews  or  ratings  - 
although they hold the data to establish the relevant percentages.  

The  Legal  Analysis  and  case  studies  found  that  most  platforms  set  minimal 
identification requirements for registration and access (e.g. name and email address), 
and  usually  do  not  adopt  adequate  measures  to  verify  users’  identity.  Almost  all 
platforms  deny  responsibility  for  the  accuracy  of  user  information.  Most  case  study 
platforms  rely  on  user  information  checks  through  email  or  social  media  accounts. 
Some offer optional identity verification services and very few require official  identity 
documents for registration. 

There is therefore a need for platforms to be transparent about the mechanisms they 
use to manage review and rating systems, and to ensure consumer understanding of 
the  underlying  quality  control  system.  Along  the  same  lines  as  the  Key  Principles  for 
Comparison  Tools,  platforms  featuring  peer  review,  rating  or  reputation  systems 
should at least be required to be clear and transparent about how they manage and/or 
verify  reviews;  publish  only  genuine  reviews  with  a  date;  and  give  information  to 
users  about  the  representativeness  and  reliability  of  user  reviews  or  ratings,  and  on 
how  positive  or  negative  reviews  or  ratings  influence  the  search  results  or  access  to 
the platform. 

The  professional  diligence  duties  and  the  transparency  requirements  of  the  UCPD,  as 
interpreted  in  the  UCPD  Guidance,  refer  to  checking  user  identity  for  example  when 
considering  that  platforms  should  ensure  that  reviews  originate  from  real  users  and 
are  not  fake.  To  deal  with  the  lack  of  identity  verification,  platforms  which  actively 
manage  or  govern  the  transactions  concluded  between  their  users,  could  further  be 
required to adopt tools that help to adequately ascertain the users’ identity. This may 
for  instance  include  ID  verification  systems  to  check  peers’  identity  at  the  time  of 
registration, interviews, and checks against official databases or similar means.  

3.  Discrepancy  between  exclusion  of  platform  responsibility  and  liability  for 
the performance of online P2P transactions and platform practices  

The business models of the largest online P2P platforms are built  on the volume and 
value  of  P2P  transactions  they  facilitate, and  on  their  -  at  least  partial  -  control  over 
the terms and quality of these P2P transactions. Most case study platforms set at least 
part  of  the  contractual  terms  of  the  P2P  transaction.  This  may  create  the  impression 
among users that the platform shares a certain degree of responsibility in case of non-
performance or non-compliance of the performance. Such impressions can for instance 
be  created  by  holding  payments  until  performance/compliance  of  the  service  is 
confirmed  or  withholding  payment  in  case  of  non-performance  or  non-compliance  by 
peers;  by  imposing  rules  and  fees  for  cancellations  by  peer  consumers  or  providers; 
and  by  intervening  to  solve  problems  between  peers  through  management  of 
complaints, mediation of disputes and award of refunds. 

But the terms and conditions of these platforms systematically exclude any liability of 
the  platform  in  relation  to  the  contracts  concluded  between  the  peers,  and  explicitly 
state  that  the  platform  is  not  a  party  to  such  contracts.  For  instance,  all  case  study 
platforms  exclude  liability  for  the  accuracy  of  information  provided  by  the  peer  to 
establish whether they are a commercial or a private provider; non-performance, non-
compliance of the performance by the peer providers; and the accuracy of information 
provided in peer-to-peer reviews.  

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The  discrepancy  between  the  platforms'  level  of  intervention  in  the  P2P  transaction 
and the liability clauses in its T&Cs risks to confuse or mislead users with regard to the 
responsibility  of  the  platform  in  case  of  problems  with  the  P2P  transaction.  Most 
importantly, in the current legal environment there is a significant lack of clarity about 
the liability of platforms that do more than mere hosting of listings. When the platform 
actively  manages  P2P  transactions,  or  governs  them  (business  models  2  and  3)  it  is 
more  likely  that  its  users  have  the  impression  that  the  platform  will  also  share  a 
certain  degree  of  liability  –  for  example  for  unlawful  behaviour  on  the  platform, 
posting  false  or  misleading  listings  or  reviews,  and  non-performance  or  poor 
performance  of  transactions.  To  deal  with  this,  stakeholders  suggested  clarifying  the 
interpretation  of  the  already  existing  obligations  arising  from  EU  legislation,  notably 
with  respect  to  platforms  that  actively  manage  and  govern  the  transaction  between 
the peers; taking legal initiatives at EU level to tailor the responsibility of the platform 
for the P2P transaction to its degree of intervention in that transaction; and testing the 
effectiveness of Codes of Conduct in addressing this. 

4. Access to redress for peer consumers and peer providers 

In most EU countries, the legal framework applicable to transactions between private 
peers, (i.e. C2C transactions) is not tailored to contracts concluded online through P2P 
platforms. For example, in C2C transactions concluded online or via online platforms, 
in  most  cases,  the  parties  or  the  good  are  not  physically  present,  the  identity  of  the 
other peer is often not clear, and part of the terms of the contract may be determined 
by the platform. While no extra regulation is necessary with regards to C2C contracts 
concluded between two parties whose identity as consumers is clear, in cases of C2C 
contracts  concluded  online,  it  could  instead  be  beneficial  to  make  existing  C2C 
legislation  fit  for  digital  purposes.  For  example,  a  recent  amendment  to  the  French 
Civil Code introduced a new provision setting out that unfair contract terms included in 
contracts whose content has been pre-formulated by one of the parties are void.  

It  could  be  assessed  whether  certain  aspects  of  national  unfair  contract  terms 
legislation  could  be  extended  to  online  C2C  contracts  where  the  content  of  the 
contract is to a large extent pre-determined by one of the parties, or by a third party, 
i.e. the platform, the parties or of the object of the contract are not physically present 
and  there  are  uncertainties  relating  to  the  actual  identity  of  one  of  the  parties.  In 
order to enhance the effective enforcement of existing C2C legislation in transactions 
on  online  platforms,  stakeholders  suggested  expanding  the  competence  of  national 
consumer  protection  authorities  to  C2C  transactions  on  online  platforms;  promoting 
the  use  of  the  European  Small  Claims  Procedure  on  online  P2P  platforms  for  online 
C2C  disputes  with  a  cross-border  element  up  to  EUR  2,000;  and  encouraging 
platforms to collaborate with competent authorities to facilitate peers’ compliance with 
local regulations.  

The  survey  indicated  that  peer  providers  and  consumers  consider  the  platform  to  be 
an  important  channel  for  resolving  issues  in  the  P2P  transaction,  and  found  a  large 
number  of  instances  where  they  obtained  solutions  through  the  platform.  The  case 
study analysis has shown that redress and refunds in case something goes wrong are 
often  left  to  the  discretion  of  the  platform  which  evaluates  complaints  on  a  “case  by 
case”  basis,  and  that  the  criteria  for  its  decisions  are  not  clearly  explained  to  peers. 
This  could  be  addressed  by  requiring  platforms  which  govern  P2P  transactions 
(business  model  3)  to  offer  clearly  explained,  platform-managed  redress  options  to 
peer  consumers  and  peer  suppliers  in  case  of  disputes.  At  a  minimum,  all  platforms 
should 
for 
cancellations/withdrawals  of  transactions  and  entitlement  to  refunds;  the  rules  that 
apply in case of non-performance or poor performance, or if the good or service does 
not fit the description, including entitlements to refunds and any administrative fees. 
Furthermore,  all  platforms  should  also  inform  peers  about  external  informal  and 
formal  redress  options,  including,  when  relevant,  Alternative  Dispute  Resolution  and 
cross border Online Dispute Resolution.  

terms  and 

rules  and 

conditions 

set  out 

their 

fees 

in 

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5. Data use and reuse 

Data use  and  reuse  are  common  among  the  platforms analysed in  this study  and  an 
essential part of their business models. Especially in the case of larger platforms these 
user data represent significant value, for the platform itself as well as for third parties, 
for price setting, dynamic pricing, marketing and other commercial purposes. But the 
information  given  by  platforms  about  their  data  use,  re-use,  sharing  and  selling 
practices is in many cases not fully transparent, and it is therefore not clear if current 
national  data  protection  rules  are  fully  respected.  In  particular,  the  case  study 
platforms do not have a clear data use policy regarding transfers to third parties. All 
indicate they share data with third parties, but they do not always mention that they 
only do so with user consent. Only BlaBlaCar mentions explicitly that they do not sell 
data to third parties.  

Such  practices,  or  lack  of  clarity  about  current  practices  of  data  use  and  reuse  raise 
concerns  regarding  the  protection  of  personal  data,  especially  when  they  are  shared 
and/or  transferred  to  third  parties  for commercial  purposes.  As  the survey and focus 
group results have shown, transparency about the personal and behavioural data that 
platforms  collect,  how  they  use  them,  who  they  share  them  with  or  sell  them  to,  as 
well  as  information  about  data  protection  rules  that  apply  is  of  utmost  important  for 
both  peer  providers  and  peer  consumers.  As  of  25  May  2018,  platforms  need  to 
comply  with  new  obligations  set  out  by  the  General  Data  Protection  Regulation 
(GDPR).  It  is  suggested  that  the  accompanying  measures  to  facilitate  the 
implementation of the GDPR include specific measures focusing on its implications for 
online P2P platforms. 

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1  Introduction  

This  is  the  final  report  submitted  as  part  of  contract  2015  86  02  signed  with  the 
Consumers, Health, Agriculture and Food Executive Agency (Chafea) on an exploratory 
study  on  consumer  issues  in  peer-to-peer  (P2P)  markets  facilitated  by  online 
platforms1. It describes all the work carried out as part of this contract and it provides 
a comprehensive analysis of all findings and conclusions including policy options. This 
final report is complemented by a series of task reports, which give further details of 
the findings discussed in this document.    

1.1  Peer to Peer online platform markets: a consumer policy perspective 

EU consumer policy in an online environment 

The aim of EU consumer policy is to maximise consumer participation and trust in the 
market. Consumer policy generally governs Business to Consumers (B2C) interactions, 
and  it  perceives  the  consumer  as  the  weaker  party  in  such  transactions.2,3  A  well-
designed  and  implemented  consumer  policy  can  lead  to  improved  transparency  and 
better  informed  choices,  which  result  in  better  solutions  for  consumers  and  greater 
market efficiency.4 

With  the  emergence  of  the  internet,  the  focus  of  EU-level  consumer  policy  shifted 
towards online purchases and practices, towards harmonising consumer rights across 
Member  States,  facilitating  cross-border  and  online  purchasing  and  promoting  best 
practices5. Today, 95% of EU consumers made at least one purchase online in the past 
12 months, while 12% of EU consumers made such purchases at least every month6.  

From  a  consumer  and  consumer  policy  perspective,  online  P2P  transactions  via 
platforms  present  both  benefits  and  challenges.  Benefits  for  consumers  may  include 
lower  prices,  efficient  use  of  under-utilised  resources  and  improved  access  to  certain 
goods. At the same time, online P2P platforms also pose challenges to policy makers, 
such as the applicability and enforcement of existing consumer protection rules which 
apply  to  B2C  transactions.  Regulatory  uncertainty  brought  about  by  the  rapid 
development  of  online  P2P  markets  could  put  consumer  interests  as  well  as  the 
sustainable development of these markets at risk.  

Online P2P platforms blur the distinction between consumer and provider 

As  illustrated  in  Figure  1,  there  are  three  key  actors  involved  in  each  P2P  online 
transaction within the scope of this study:  

1.  The online platform which - at its most basic - acts as a “matchmaker” bringing 
together demand for and supply of a good or service to be rented, hired, sold, 

1 The original title of the contract was for an “exploratory study on consumer aspects in the sharing economy”. It was agreed over 
the course of the study that, given ongoing debate regarding the definition of the “sharing economy”, the focus of the study was best 
reflected in the notion of “peer to peer markets facilitated by online platforms”.  
2 Koopman, C., Mitchell, M., Thierer, A. (2015). The Sharing Economy and Consumer Protection Regulation: The 
Case for Policy Change. The Journal of Business, Entrepreneurship & the Law, 8(2). Available at: 
https://www.mercatus.org/system/files/Koopman-Sharing-Economy.pdf  
3 United Nations Conference on Trade and Development (2016). United Nations Guidelines for Consumer 
Protection. Available at: http://unctad.org/en/PublicationsLibrary/ditccplpmisc2016d1_en.pdf  
4 European Parliament (2014). Study on Consumer protection aspects of financial services. Available at: 
http://www.europarl.europa.eu/RegData/etudes/etudes/join/2014/507463/IPOL-IMCO_ET(2014)507463_EN.pdf 
5 European Commission (2012). Staff Working Document Consumer Empowerment in the EU. Available at: 
http://ec.europa.eu/consumers/archive/strategy/docs/swd_document_2012_en.pdf  
6 European Commission (2015). Provision of two online consumer surveys as support and evidence base to a 
Commission study: Identifying the main cross border obstacles to the Digital Single Market and where they matter 
most. Available at: 
http://ec.europa.eu/consumers/consumer_evidence/market_studies/obstacles_dsm/docs/21.09_dsm_final_report.
pdf  

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exchanged or shared. The platform may also supply peers with services such as 
instant messaging, review systems, background checks, insurance etc. 

2.  One “peer” acting as the provider / seller of the good or service to be shared or 

exchanged (peer provider); and 

3.  One  “peer”  acting  as  the  consumer  /  purchaser  of  the  good  or  service  to  be 

shared or exchanged (peer consumer).  

At  any  point  in  time,  a  given  peer  consumer  can  be  considered  as  a  recipient  of  a 
service/good provided by a peer provider, and as a user of services by a P2P platform. 
Similarly, in addition to their main role of providing a good or service, peer providers 
are also users of services provided by the P2P online platform. 

Figure 1 : Different layers of rule-making on online P2P platforms 

Source:  OECD  (2016).  Protecting  Consumers  in  Peer  Platform  Markets:  Exploring  the  issues.  OECD  Digital 
Economy Papers (253). 

Thus,  P2P  platforms  operate  as  two-sided  markets  bringing  together  actors  on  the 
demand and supply sides.  7 On the supply side, these actors are providers /sellers of 
goods/services;  on  the  demand  side,  they  are  consumers  or  buyers  -  both  can  be 
referred  to  as  peers,  platform  peers  or  platform  users.  The  same  platform  peer  may 
perform  the  role  of  both  peer  provider  and  peer  consumer,  across  multiple 
transactions on the same or on different platforms. 

This  blurring  of  the  distinction  between  consumers  and  providers  makes  transactions 
in  online  P2P  markets 
from  traditional  offline  B2C 
transactions: 

fundamentally  different 

  Consumers  have  a  more  active  role  in  the  transactions  than  in  traditional 

markets, also acting as producers or reviewers; 

  P2P platforms act as intermediaries and do not provide the goods/services that 

are the subject of the transactions they facilitate themselves; 

  Data  on  peer  behaviour  is  intensely  used  by  P2P  platforms,  which  may  pose 

issues related to privacy, reputation and switching costs.8 

7 Martens, B. (2016). An Economic Policy Perspective on Online Platforms. Digital Economy Working Paper 
2016/05. JRC Technical Reports. 
8 OECD (2016). Protecting Consumers in Peer Platform Markets: Exploring the issues. OECD Digital Economy 
Papers (253).  

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The need to explore the impact of online P2P markets on consumer aspects 

In addition to setting out the main actors, Figure 1 above also illustrates the different 
layers  of  rule-making  that  currently  govern  online  P2P  transactions.  Some  of  these 
result from the application of existing consumer and marketing law. Others are set by 
online  P2P  platforms  themselves  in  Terms  and  Conditions,  Privacy  Policies  or 
Community  Guidelines9,  or  intended  to  foster  consumer  trust  in  online  peer  to  peer 
markets  e.g.  peer  reviews/ratings,  user  reputation  tools,  or  complaint,  redress  and 
insurance  systems.  There  is  evidence  that  such  voluntary  rule-making  by  online  P2P 
platforms  themselves  can  be  useful:  a  PwC  (2016)10  study  finds  that  64%  of  peers 
consider  peer  regulation  through  platforms  more  important  than  government 
regulation.  

At  the  same  time,  the  fundamental  objectives  of  consumer  policy  remain  relevant  in 
online  P2P  markets11.  Transparency  and  easy  access  to  information,  safety  of 
transactions  and  payments,  fair  Terms  and  Conditions  or  effective  dispute  resolution 
remain important for peers and it is not clear if voluntary action alone can effectively 
deliver these outcomes. Voluntary initiatives are promoted through incentives, rather 
than  enforced  through  sanctions12  and  platforms  “may  have  little  monetary  incentive 
to  address  issues  that  impose  costs  only  on  third  parties”  but  both  the  platform  and 
peer providers “may have an interest in addressing such harms if they could be liable 
to third parties for such harms” 13. 

1.2  Aims and objectives of this study 

This study is undertaken within the scope of an action covered by Objective 3 of the 
European  Commission’s  work  programme  for  201514  within  its  multiannual  consumer 
programme  for  the  2014-2020  programming  period.  Objective  3  aims  for  the 
development  and  reinforcement  of  consumer  rights,  through  smart  regulatory  action 
and  improving  access  to  simple,  efficient,  expedient  and  low-cost  redress  including 
alternative dispute resolution15.  

The  overall  objective  of  the  present  -  exploratory  -  study  is  to  construct  a  picture  of 
the  main  P2P  markets  and  to  identify  the  main  issues  from  a  consumer  policy 
perspective.  

The  study  objective  is  achieved  through  collecting  primary  and  secondary  data  from 
EU Member States and Norway to provide an exploratory analysis of the: 

 

Indicative  economic  importance  of  P2P  markets  facilitated  by  online  platforms 
in the EU Member States, and the main P2P business models; 

  Main experiences, perceptions, expectations and problems of consumers/users 

in P2P markets facilitated by online platforms in 10 EU Member States; 

9 Examples of community guidelines include AirBnB’s hospitality standards, Peerby’s rules, or BlaBlaCar’s Rideshare 
agreement. These guidelines are described in detail in the case studies under Task 4. 
10 PwC (2015). The Sharing Economy. Consumer Intelligence Series. Available at: 
http://www.pwc.com/us/en/industry/entertainment-media/publications/consumer-intelligenceseries/assets/pwc-
cis-sharing-economy.pdf  
11 OECD (2016). Protecting Consumers in Peer Platform Markets: Exploring the issues. OECD Digital Economy 
Papers (253). 
12 E.g. through additional benefits to peers that comply, such as AirBnB’s super host badge, or Peerby’s green 
verification circle – see Task 4 case studies. 
13 US Federal Trade Commission (2016). The “Sharing Economy”. Issues Facing Platforms, Participants & 
Regulators. An FTC Staff Report. Available at: https://www.ftc.gov/system/files/documents/reports/sharing-
economy-issues-facing-platforms-participants-regulators-federal-trade-commission-
staff/p151200_ftc_staff_report_on_the_sharing_economy.pdf  
14 As adopted by the Commission Implementing Decision C(2014)9393 final of 11 December 2014. 
15 Article 3(1)(c) of Regulation (EU) No 254/2014. 

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  Relevance  of  the  EU  consumer  acquis  and  other  related  EU  and  national 
legislation in addressing specific issues and problems in the main P2P business 
models, and in its enforcement; 

  Transparency  of  business  models  and  effectiveness  of  self-regulatory 
for  trust  building,  verification,  redress/complaint  handling, 

mechanisms 
fulfilling tax obligations as operated by online P2P platforms,  

  Policy options for resolving any major issues or problems identified. 

1.3  The scope of the study  

To  examine  the  user  and  consumer  aspects  and  issues  in  online  P2P  markets  the 
scope of the study must be clearly defined. This sub-section presents and explains the 
study’s focus.  

First,  this  study  focuses  on  peer  to  peer  transactions  in  markets  facilitated  by  online 
platforms. The OECD has defined "peer platform markets" as a wide range of new and 
emerging  production  and  consumption  models  that  involve  the  commercial  exchange 
of goods and services between peers through online platforms (websites or apps). This 
study thus has a different focus than publications that refer to the “sharing economy” 
or the “collaborative economy”. For instance, the European Commission has16 defined 
the  collaborative  economy  as  “business  models  where  activities  are  facilitated  by 
collaborative  platforms  that  create  an  open  marketplace  for  the  temporary  usage  of 
goods or services often provided by private individuals”.  

Second,  the  study  only  covers  P2P  transactions  facilitated  online  where  peers  do  not 
know each other personally. This delimitation ensures that the platforms considered in 
this  study  are  accessible  to  a  broad  range  of  peer  consumers.  Therefore,  P2P 
transactions  that  occur  through  direct  personal  contact,  sharing  arrangements 
between  closed  groups  or  friends  and  family,  or  where  the  sharing  offer  is  not 
addressed  to  the  public  are  not  considered.  Platforms  such  as  BroodFonds  in  the 
Netherlands, are thus excluded. 

Third, the study considers only five sectors of activity, namely: 

  Selling  or  buying  goods  from  other  people  -  (Re)Sale  of  Goods:  They  include 
classified  listings  websites  such  as  Gumtree  in  the  UK,  Kapaza  in  Belgium, 
Marketplaats  in  the  Netherlands,  or  LeBonCoin  in  France.  They  also  comprise 
marketplaces  for  specific  items  such  as  cars  (e.g.  the  Bulgarian  platform 
Car24), clothes (e.g. Trendsales in Denmark), (Cyklobazar in Czech Republic); 

  Sharing  and  renting  goods  from  other  people  -  Sharing/Renting  Goods:  Some 
platforms allow to share or request items from people in their neighbourhood, 
such as Peerby in the Netherlands, or Skylib in Norway; or from anywhere (e.g. 
Trovit  in  the  UK).  Some  other  platforms  focus  on  specific  items,  such  as 
Kleiderkreisel  in  Austria  (clothes),  Parking  Motel  in  Italy  (parking  spots), 
Jestocke in France (storage options); 

  Sharing  or  renting  accommodation  from  other  people  -  Sharing/Renting 
Accommodation:  They  include  platforms  to  find  a  long-term  accommodation 
(e.g.  SpareRoom  in  the  UK,  Stancja  in  Poland),  holiday  rentals  (e.g.  the 
Maltese  platform  Malta  holidays,  the  Lithuanian  platform  Trumpam),  house 
sharing  (e.g. 
types  of 
the  French  platform  Appartager)  or  specific 
accommodation (e.g. the Greek-based platform Campinmygarden); 

16  EC: (2016): A European agenda for the collaborative economy, COM (2016) 356 final 

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  Sharing or hiring a ride from other people - Sharing/Hiring Rides: Platforms of 
this  category  offer  ride-sharing  services  (e.g.  the  Estonian-based  platform 
Taxify),  carpooling  opportunities  (e.g  the  French  BlaBlaCar,  or  the  Hungarian 
Autosztunk), or car-rental options (e.g. Mobocar in Latvia). Some also offer to 
rent specific cars, such as motorhomes (e.g. Rentmymotorhome in the UK) or 
vans (e.g. Areavan in Spain);  

teaching  (e.g.  Professeurparticulier 

  Hiring  other  people  to  do  odd  jobs  -  Odd  jobs:  platforms  for  hiring  non-
professional people to perform personal services. The range of services offered 
in 
includes 
Germany),  cooking  (e.g.  Foodora  in  Italy),  tourism  guide  services  (e.g. 
Trip4Real  in  Spain),  or  dog-sitting  (e.g.  Housemydog  in  Ireland).  Some,  like 
the Polish platform Skill Trade, offer a broader range of services from design to 
painting or plumbing.  

in  Belgium,  Skillshare 

In  addition,  in  line  with  the  specifications,  certain  types  of  platforms  were  excluded 
from  the  scope.  These  include  all  platforms  facilitating  transactions  in  customised  or 
tailor-made  goods,  in  cultural  products  (books,  films,  DVDs,  CDs,  theatre  tickets)17, 
food-sharing  activities  and  real  estate  transactions18,  professional  services  (e.g.  legal 
advice,  accounting  and  medical  services,  etc.)19,  crowdfunding/money  lending 
platforms;  and  all  platforms  facilitating  B2C  transactions  such  as  regular  B2C  rental 
markets and B2C vehicle loan systems20 . 

Fourth, the study excludes platforms which do not pursue a commercial purpose (not-
for-profit,  charitable  private  initiatives).  The  study  is  limited  to  P2P  platforms  with  a 
profit seeking motive, either financially benefiting from a monetary exchange with and 
between the peers or via data use and reuse.  

Fifth  and  finally,  the  study’s  overall  geographical  scope  includes  all  EU  28  Member 
States  plus  Norway.  The  basis  of  the  assessment  is  not  where  the  platform  is 
headquartered  but  whether  it  operates  in  at  least  one  of  the  countries  within  its 
geographical scope. 

17 The exclusion of platforms such as eBay’s StubHub, an entertainment tickets (re)sale platform, was decided 
because of specific copyright issues related to such products. 
18 Food-sharing platforms like EatWith or ShareYourMeal, as well as real estate P2P platforms like Landbuy or 
LendInvest were excluded because of specific regulatory issues in their sectors of activity. 
19 Professional services platforms like Freelancer.Com were excluded because they raise specific qualifications and 
employment issues. 
20 For instance,like ZipCar in the UK or Cambio in Belgium. 

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2  Methodological approach  

This  section  presents  a  brief  overview  of  the  methodology  adopted  in  each  of  the 
study  tasks.  Further  detail  on  the  methodological  approach  can  be  found  in  the 
respective task reports (see annexes). 

2.1  Task 1 - Desk research and literature review 

During Task 1, two data collection activities were conducted, namely: 

1.  A  comprehensive  literature  review  covering  scientific  publications  and  grey 
literature  from  across  the  EU-28  and  beyond  (conducted  March-June  2016)21; 
and  

2.  A  large-scale  desk  research  exercise  to  identify  and  screen  485  online  P2P 
platforms  from  the  28  EU  countries  and  Norway  (conducted  March-December 
2016). 

The  platform  selection  emphasised  autochthonous  platforms  (i.e.  platforms  created 
nationally/locally) in each country to get a picture of the P2P market in each country. 
Where  autochthonous  platforms  could  not  be  found,  popular  platforms  from  other 
(often neighbouring) countries operating and with a large peer base in the country of 
study were included. Of the 485 platforms in the sample, only three (AirBnB, Uber and 
eBay) were established outside of the EU or Norway. These platforms were included in 
the  study  given  their  popularity  and  because  they  have  a  registered  office  in  an  EU 
country (Ireland for AirBnB and UK for Uber and eBay). 

The  aim  of  the  screening  was  not  to  provide  a  complete  inventory  of  P2P  platforms, 
but to have a sample that includes platforms in all relevant sectors of activity. Initially, 
the selection aimed to identify five platforms per sector per country, leading to up to 
25  platforms  per  country.  This  was  not  always  possible,  given  the  different  market 
sizes.  In  larger  markets  like  France,  the  UK  or  Germany  5  or  more  platforms  were 
found  in  each  sector.  In  smaller  markets  such  as  Latvia,  Croatia  or  Slovakia  only  a 
handful of relevant platforms were identified. In countries with over 25 platforms, the 
selection  was  focussed  on  the  most  popular  platforms  in  terms  of  daily  unique 
visitors.22.  

Platforms  were  selected  using  local  experts  as  well  as  desk  research  (e.g.  grey 
literature,  websites  of  consumer  associations,  consumer  blogs  and  forums,  media). 
Desk  research  was  combined  with  the  survey  data  from  Task  2  to  identify  the  most 
commonly-used  online  P2P  platforms  in  each  country  for  each  of  the  five  sectors 
included in the scope of the study. Of the 485 platforms identified in Task 1, 10 were 
selected for a more in-depth analysis as part of the Task 4 case studies. The selection 
was done in agreement with the European Commission based on popularity in terms of 
daily unique visitors, and sectorial coverage. 

The  table  below  outlines  the  number  of  platforms  per  country  and  per  sector  which 
were screened during Task 1. 

Table 1: Number of P2P platforms per country and sector included in Task 1   

 Country  

(Re)sale of 
goods  

Sharing/ren
ting goods  

Sharing/hiri
ng rides  

Sharing/ren
ting 
accommoda
tion  

Odd jobs  

Total - 
collaborativ
e platforms 
(excluding 

Total all 
platforms 

21 The date of June 2016 refers to the conclusion of the the systematic literature review across all countries covered. Where the study 
team became aware of additional relevant material after that date, this was of course still included in the analysis. 
22 See Task 1 report annex for a dull list of platforms included in the analysis. 

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Austria 
Belgium  
Bulgaria 
Cyprus  
Czech 
Republic  
Germany  
Denmark  
Estonia 
Spain 
Finland 
France 
Greece 
Croatia 
Hungary 
Ireland 
Italy 
Lithuania 
Luxembourg  
Latvia 
Malta 
Netherlands 
Norway 
Poland 
Portugal 
Romania 
Sweden  
Slovenia 
Slovakia 
UK 
Total  

6 
6 
10 
8 

6 

5 
5 
5 
5 
5 
5 
5 
5 
8 
1 
5 
9 
4 
2 
5 
9 
5 
5 
5 
6 
6 
5 
4 
7 
162 

3 
4 
1 
0 

4 

5 
6 
3 
5 
2 
5 
1 
0 
1 
4 
6 
3 
1 
0 
3 
3 
1 
5 
2 
4 
4 
2 
0 
4 
82 

1 
6 
8 
2 

1 

7 
4 
4 
5 
3 
5 
2 
1 
4 
0 
5 
0 
1 
1 
1 
5 
2 
7 
3 
2 
0 
3 
0 
6 
89 

6 
6 
0 
3 

1 

4 
2 
0 
4 
1 
5 
0 
0 
3 
4 
0 
4 
7 
0 
2 
4 
1 
3 
3 
1 
2 
3 
2 
5 
76 

re-sale of 
goods) 

14 
23 
11 
6 

6 

21 
17 
8 
18 
7 
20 
5 
1 
9 
12 
15 
11 
9 
1 
6 
19 
7 
20 
10 
8 
7 
9 
2 
21 
323 

4 
7 
2 
1 

0 

5 
5 
1 
4 
1 
5 
2 
0 
1 
4 
4 
4 
0 
0 
0 
7 
3 
5 
2 
1 
1 
1 
0 
6 
76 

20 
29 
21 
14 

12 

26 
22 
13 
23 
12 
25 
10 
6 
17 
13 
20 
20 
13 
3 
11 
28 
12 
25 
15 
14 
13 
14 
6 
28 
485 

The  detailed  output  of  this  task  is  presented  in  the  Task  1  report.  Key  findings  are 
reported  in  the  present  final  report.  The  Task  1  report  addresses  the  following 
requirements of the terms of reference for this study:  

1.  An indication of the economic importance of the P2P market sectors facilitated 
by  online  platforms  and  of  P2P  cross-border  transactions  in  the  28  Member 
States; and 

2.  A  typology  of  the  main  business  models  in  P2P  markets  facilitated  by  online 

platforms as relevant from a consumer perspective.  

2.2  Task 2 – Survey  

This task focused on the collection and analysis of P2P market user data. The survey is 
a  standard  online  survey  measuring  respondents’  attitudes  and  self-reported 
behaviour with their experiences as peer consumers and peer providers on online P2P 
platforms.  

The survey was conducted in 10 EU Member States, using the GfK consumer panels23. 
A  representative  sample  of  the  online  population  (aged  18  years  or  older)  in  each 
country was screened on their experience with five categories of online P2P platforms. 
Based on this screening questionnaire, respondents were selected if they had used one 
or more of the P2P platforms within the scope of this study, resulting in about 1,000 
users of P2P platforms in each country (see Table 2).  

23 http://www.gfk.com/solutions/consumer-panel/ 

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Respondents were selected when they had acted as peer consumers, peer providers or 
both in the last 12 months. Respondents with both peer consumer and peer provider 
experience  first  answered  the  questionnaire  from  the  perspective  of  the  peer 
consumer and  then  from the  perspective of  the  peer provider.  Respondents who  had 
experience  with  more  than  one  platform,  were  asked  to  complete  the  questionnaire 
twice:  for  two  different  platforms  as  a  user  or  as  a  provider.  Respondents  that  had 
experience with multiple platform types, were allocated to the platform type for which 
the  lowest  number  of  responses  had  been  obtained.  The  length  of  the  survey  was 
between 10 and 15 minutes per platform.  

The  survey  was  piloted  on  at  least  50  respondents  in  each  country  to  check  data 
quality and to identify additional relevant online P2P platforms for inclusion in the pre-
defined list of platforms in the questionnaire.  

Following the pilot, the full survey was launched on 4 May 2016 and closed on 18 May 
2016.  The  table  below  provides  an  overview  of  the  sample  size  obtained  in  each 
country.  

Table 2: Sample size in Task 2 survey 

Country 
Bulgaria 
Denmark 
France 
Germany 
Italy 
The Netherlands 
Poland 
Slovenia 
Spain 
UK 
TOTAL 

Sample size 
1,002 
1,000 
1,001 
1,003 
1,000 
1,003 
1,004 
1,003 
1,001 
1,002 
10,019 

The  detailed  output  of  this  task  is  presented  in  the  Task  2  report.  Key  findings  are 
reported  in  the  present  final  report.  The  task  2  report  addresses,  together  with  the 
Task  3  focus  group  report,  the  following  elements  in  the  terms  of  reference  for  this 
study:  

  Measure participation in P2P transactions / registration on P2P platforms; 

  Assess P2P experiences of active peer-suppliers and peer-consumers, including 
the  type  of  problems  encountered  and  action  taken  to  solve  problems  or 
complaints; 

  Assess  expectations  and  satisfaction  with  peer  review/rating  systems, 
verification  and  complaint  handling  by  online  platforms  facilitating  P2P 
transactions;  as  well  as  expectations  regarding  consumer  rights/protection  in 
P2P context/communities, awareness of risk of engaging in P2P; 

 

Identify obstacles to engaging (more) in P2P transactions. 

2.3  Task 3 – Focus groups 

To  gain  a  deeper  understanding  of  the  behaviour  of  peers,  focus  groups  with  peers 
active  on  relevant  online  P2P  platforms  were  organized  in  each  of  the  10  countries24 

24  The  cities  where  the  fieldwork  took  place  are  London  (UK),  Milan  (Italy),  Paris  (France),  Nürnberg 
(Germany),  Madrid  (Spain),  Warsaw  (Poland),  Ljubljana  (Slovenia),  Sofia  (Bulgaria),  Hilversum  (The 
Netherlands) and Kopenhagen (Denmark).  

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included  in  the  consumer  survey.  Preliminary  findings  from  the  survey  were  used  to 
elaborate the focus groups guidelines.  

Fieldwork took place in the week of 23rd to 27th of May. A 2-hour focus group was held 
in  one  city  in  each  country  with  a  minimum  of  7  or  8  active  users  of  online  P2P 
platforms.  Participants  were  recruited  via  specialised  agencies  and  in  line  with  the 
screening criteria in table 3 used:  

Table 3: Task 3 criteria for focus group recruitment   

Topic 
Gender 

Age 

Education 

Experience 

Type of platform used 

Criterion 
Male 
Female 
18-34 
35-54 
55+ 
secondary education 
tertiary - vocational 
tertiary - higher education 
as peer-consumer 
as peer-supplier 
(re)sale of goods 
sharing/renting goods 
sharing/renting accommodation 
sharing/hiring rides 
odd jobs  

Quota 
min. 3 
min. 3 
min. 4 
min. 2 
min. 1 
min. 1 
min. 1 
min. 2 
min. 3 
min. 3 
min. 1 
min. 1 
min. 1 
min. 1 
min. 1 

The  detailed  output  of  this  task  is  presented  in  the  Task  3  report.  Key  findings  are 
reported  in  the  present  final  report.    The  Task  3  report  addresses  the  following 
elements in the terms of reference for this study:  

  Further  explore  P2P  experience,  perceptions,  problems  and  expectations  with 

richer qualitative information; and  

  Gather insights about the underlying attitudes of peers to P2P market activities 

and the performance of online platforms in particular. 

2.4  Task 4 – Case studies 

The aim of task 4 was to assess platform transparency, and the effectiveness of trust 
building and verification mechanisms, as implemented by a selection of P2P platforms 
in the five sectors of activity, and  representing some of the main business models in 
P2P markets. To do this, 10 platform case studies were carried out: Yoopies, Wimdu, 
Wallapop,  EasyCarClub,  Nimber,  Peerby,  BlaBlaCar,  AirBnB,  Uber  Pop/Pool,  eBay 
between June and December 2016. 

Each case study included:  

  Qualitative  interviews  with  representatives  of  platforms  (semi-structured,  via 

telephone and face-to-face when possible); 

  Document analysis (company documents, reports and studies); 

  Analysis of the online platform; and 

  Mystery shopping.  

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The interpretative synthesis of these different data sources provided the basis for the 
analysis of each case25. In-depth interviews were carried out to capture non-codified, 
tacit information and assessments.  

The  detailed  output  of  this  task  is  presented  in  the  Task  4  report  which  includes  the 
cross-analysis of all 10 case studies as well as 10 standalone case study reports (1 per 
platform).  Key  findings  are  reported  in  the  present  final  report.  The  task  4  report 
addresses the requirement in the terms of reference to gather in-depth data about:  

  Transparency:  clarity  about 

identities  of  peers  and  platforms, 
responsibilities, insurance and recourse/redress mechanisms, tax obligations;26 

legal 

  Trust  building  (ratings,  pictures)  and  verification  of  peer  information  and 

criteria;  

  Access 

to  private/self-regulatory 

complaints, 

redress  and 

insurance 

mechanisms; and 

 

Information to platform users: terms and conditions, data protection. 

2.5  Task 5 – Legal Analysis  

The  Legal  Analysis  identified  and  analysed  the  national  legislation  distinguishing 
between  B2C  and  C2C  transactions,  as  well  as  national/regional  and  local  provisions 
applying  to  C2C  transactions  and  online  platforms  facilitating  P2P  transactions.  This 
formed tha basis for assessing the relevance of the EU consumer acquis and Member 
State legislation and identifying gaps and problems that national authorities encounter 
in  applying  the  relevant  national  rules,  both  nationally  and  in  cross-border 
transactions.  Task  5  also  gives  an  overview  of  relevant  legal  and  policy  initiatives, 
already adopted or in the pipeline.  

The  cut-off  date  for  the  Legal  Analysis  was  the  end  of  May  2016.  However, 
developments  occurring  after  that  date  up  until  the  end  of  September  2016  were 
considered wherever possible.  

The methodological approach adopted consisted of three main steps: 

1.  EU-level research aimed at giving a brief overview of the EU acquis relevant to 
online  platforms  facilitating  P2P  transactions,  or  that  could  be  relevant  to  P2P 
transactions, as well as relevant EU case-law.  

2.  National-level  research  across  the  EU-28  Member  States  aimed  at  identifying 
and  analysing:  i.  national  indicators  distinguishing  between  B2C  and  C2C 
transactions; ii. national legislation applicable to C2C transactions; iii. national 
rules  applicable  to  online  platforms  facilitating  P2P  transactions;  iv.  any 
relevant  specific  national,  regional  or  local  measure  taken  by  Member  States; 
v.  relevant national case-law., To validate the findings of the national research 
and  gather  more  practical  data  and  information,  the  national  experts 
interviewed an average of three national stakeholders per Member State. 

3.  The cross-analysis aimed at identifying the main consumer issues within online 
P2P  markets,  especially  those  with  a  cross-border  element.  For  this  purpose, 
the  Legal  Analysis  Team  compared  the  findings  of  the  EU-level  and  national-

25 Yin, Robert K.: Case Study Research – Design and Methods (2003), Sage Publications 
26 The terms of reference also mentioned the need to distinguish between non-profit and for profit platforms 
– since not for profit platforms were out of scope of the study, this element was not covered in the report  

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level research, as well as the results of the stakeholder consultation carried out 
by national experts. 

The detailed output of this Task is presented in the Task 5 Legal Analysis Report. Key 
findings  are  reported  in  the  present  final  report.  The  Task  5  Report  addresses  the 
following objectives:  

  Analyse  the  extent  to  which  EU  consumer  law  Directives  are  relevant  to  C2C 

transactions and online platforms facilitating P2P transactions; 

  Analyse  the  key  national-level  indicators  used  in  the  Member  States  to 
distinguish between B2C and C2C transactions and related application problems 
experienced by national authorities; 

  Map  the  national  legislation  of  all  EU  Member  States  relevant  to  C2C 
transactions  and  analyse  relevant  rights  and  obligations  of  private  individuals 
covered by this legislation compared to consumer rights guaranteed under the 
national legislation applicable to B2C transactions; 

 

 

Identify  and  analyse  national  rules  applicable  to  online  platforms  facilitating 
P2P  transactions  concerning  the  role  and  responsibilities  of  platforms  towards 
peers and related potential issues for peer consumers and suppliers; 

Identify any issues or problems that national authorities encounter in applying 
the  relevant  national  rules  and  their  application  to  cross-border  transactions 
facilitated by platforms, as well as any relevant EU and national case-law which 
may  have  caused  adaptations  or  changes  in  the  relevant  national  legal 
framework or highlighting how these rules are applied in practice; 

  Give  an  overview  of  legal  and  policy  initiatives  being  pursued  at  national, 

regional and local levels. 

2.6  Task 6 – Workshops 

As  part  of  the  study,  two  workshops  were  held  with  selected  stakeholders,  including 
EU,  national  and  regional  policy  makers,  representatives  of  the  platforms  and 
consumer associations.  

  The  first  workshop  focused  on  economic  issues  related  primarily  to  the 
preliminary  results  of  Task  1  of  the  study  as  well  as  early  findings  of  Task  2 
(consumer survey). The first workshop was held in London on May 12, 2016.  

  The  second  workshop  took  place  in  Brussels  on  October  3,  2016.  During  the 
workshop  selected  stakeholders  discussed  the  draft  results  of  the  study  and 
they worked together on potential responses to any consumer issues raised by 
the research.  

Both workshop agendas and list of participants are presented in Annexes.  

The  detailed  output  of  this  task  is  presented  in  two  Task  6  workshop  reports.  Key 
findings  are  included  in  the  present  final  report  document.  The  two  workshops 
together address the following elements in the terms of reference for this study:  

28 

 
 
 
 
 
Exploratory study of consumer issues in online peer-to-peer platform markets –  
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  Present and discuss preliminary findings of the study; 

  Discuss  relevant  (policy)  initiatives  in  Member  States  and  assess  their 

(potential) effectiveness in enhancing transparency and legal certainty; 

  Discuss  theoretical  and  practical  (policy)  options  for  improving  transparency 
and  legal  clarity  such  as  reactive  adaptation,  dual  regulation,  self-regulation, 
awareness raising and their respective advantages/disadvantages; 

  Discuss issues raised by the Legal Analysis and their impact on innovation and 

growth in the P2P markets facilitated by online platforms; 

  Develop  options  for  improving  transparency  and  legal  clarity  to  effectively 
address issues and problems in transactions in the P2P markets covered by the 
study; and 

  Develop  options 

taking  subsidiarity  and 
proportionality  of  actions  or  measures  vs.  fragmentation  resulting  from 
different policy interventions in Member States into account. 

follow-up  at  EU 

level, 

for 

2.7  Data availability and data gaps  

Throughout the above tasks, one of the key challenges of the study related to gaps in 
data  availability  on  certain  platform  characteristics.  These  included  for  instance, 
financial  records  (revenue,  profitability),  figures  on  the  number  of  active  peers  per 
country  or  on  mobile  apps,  or  information  on  the  monetisation  of  user  data.  Further 
research  into  these  fields  would  be  beneficial  to  complement  the  findings  of  the 
present study 

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3  State of play of online P2P platform markets 

This  section  provides  an  overview  of  the  main  P2P  markets  facilitated  by  online 
platforms  in  the  EU-28  and  Norway,  as  well  as  an  indication  of  the  economic 
importance of the sectors of activity within scope of the study and of P2P cross-border 
transactions.  

3.1  Size of P2P platforms 

Among  the  485  platforms  screened  for  this  study  there  are  large  differences  in 
platform  size  insofar  as  can  be  deducted  from  unique  visitor  numbers  of  websites, 
both  between  the  P2P  markets  and  within  them.  A  large  majority  of  the  platforms, 
81%  of  the  485  platforms  in  the  sample,  are  small  or  medium-sized  (below  10,000 
daily visitors) while 20 platforms (4%) are very large, with more than 100.000 unique 
visitors per day. Depending on the sector, 21 to 41% of platforms examined operate 
an  app,  either  exclusively  or  in  addition  to  a  website  –  no  data  for  app  use  were 
available. The websites of (re)sale platforms are by far the most visited and it is in this 
sector where there are the largest differences in platform size or popularity.   

3.2  Overview of services offered by P2P platforms 

Figure  2  shows  the  range  of  services  that  online  P2P  platforms  provide,  categorised 
according  to  the  point  at  which  they  occur  in  the  P2P  transaction.  The  selection  of 
these  services  was  shaped  by  academic  research  in  P2P  markets  as  well  as  by 
empirical research  on 485 P2P platforms which were screened for this study. The list 
of  services  includes  elements  such  as  pre-contractual  information,  Terms  and 
Conditions, payments, complaints handling and access to redress mechanisms, which 
are  considered  relevant  from  a  consumer  policy  perspective  –  for  example  by  the 
OECD (2016)27,  as well as trust building tools such as reputational review and rating 
systems, identity verification, and insurance, which are often cited in literature28,29.  

27 OECD (2016). Protecting Consumers in Peer Platform Markets: Exploring the issues. OECD Digital Economy 
Papers (253). 
28 Allen, D. and Berg, C. (2014). The sharing economy. How over-regulation could destroy an economic revolution. 
Available at:  https://ipa.org.au/portal/uploads/Sharing_Economy_December_2014.pdf  
29 Anders Hansen Henten, Iwona Maria Windekilde, (2016) "Transaction costs and the sharing economy", info, Vol. 
18 Iss: 1, pp.1 – 15. Retrievable at: http://www.emeraldinsight.com/doi/pdfplus/10.1108/info-09-2015-0044  

30 

 
 
 
                                                 
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Figure 2: Services provided by P2P platforms 

Source: VVA 

Pre-transaction services create the conditions for peers to enter into a P2P transaction 
on  the  platform.  These  services  may  help  lower  transaction  costs30,  encourage  peers 
to  register  on  the  platform,  or  create  a  trustworthy  environment  through  e.g.  peer 
review  systems,  user  identity  verifications  or  platform  information  regarding  rules  or 
safety.  From  a  consumer  protection  perspective,  services  at  this  stage  of  the 
transaction should help improve transparency and allow peers to make well-informed 
decisions. 

Transaction services determine the way the actual transaction occurs. This can include 
rules  pertaining  to  the  transactions  (i.e.  Terms  and  Conditions),  systems  for  setting 
prices  or  providing  pricing  guidance  and  facilitating  payments.  From  a  consumer 
protection perspective, platforms should ensure that payments are secure and that a 
clear set of rules is in place to govern transactions. 

Finally,  among  post  transaction  services,  platforms  engage  in  user  monitoring  (for 
instance  to  identify  professional  traders  or  fraudulent  users),  complaints  handling, 
facilitating  contacts  between  peers  in  case  of  complaints,  and/or  mediating  and 
seeking,  imposing  or  offering  solutions  and  redress.  This  may  also  include  tax 
collection  services  on  behalf  of  peer  providers  or  assistance  with  tax  declarations31. 
From  a  consumer  protection  perspective,  there  is  a  need  to  have  a  clear  post-
transaction process, as well as rules regarding responsibility and liability in case there 
are any issues with the transaction between the peers, or in the relationship between 
peers and platform (including e.g. data re-use).  

The  table  below  summarises  the  different  services  provided  by  platforms  to  peers 
captured in this study by stage and type and gives a brief description of each type of 
service as used in the remainder of the study.  

30  Allen,  D.  and  Berg,  C.  (2014).  The  sharing  economy.  How  over-regulation  could  destroy  an  economic 
revolution. Available at:  https://ipa.org.au/portal/uploads/Sharing_Economy_December_2014.pdf 
31 For example, platforms such as Yoopies assist peer providers with filling in their tax declaration. 

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Table 4: Overview of P2P platform services  

Stage  of  the 
transaction 

Service type 

Service description 

Regulatory 
information 

Information  on  rules  & 
taxes 

Advice/rules on safety 

Pre-
screening 

Identity 
verification 

Criminal 
records 
check 

Verification 
of 
documents 

identity 

User  information  checks 
(through  email  or  social 
media) 

Pre-
transaction 

Demand & supply matching 

Add-on services 

Peer  review  and  rating 
system 

Peer  review 
& 
Reputation 
system 

Reputation system 

Information  on  the  applicable  rules 
in the sector (e.g. health and safety 
rules,  local  regulations,  etc.)  and 
potential  tax  implications  of  P2P 
transactions. 

Advice  on  how  to  ensure  safety  in 
P2P  transactions  for  peers,  and  /or 
rules on how to enforce safety. 

Background  check  of  the  peers’ 
criminal history. 

Verification 
identity 
documents (passports or national ID 
cards) provided by peers,  

official 

of 

Opportunity to confirm user 
information and identity through 
automated email or phone and links 
to social media accounts or other 
background checks. 
Tools  used  to  actively  stimulate  the 
matching  between  peer  providers 
and  peer  consumers,  such  as 
advanced 
functions, 
search 
geolocation,  matching  algorithms, 
etc. 

Provision  of  add-on  services  to  the 
P2P  interaction,  including  advice  on 
enhanced 
listings, 
presenting 
promotion 
listings, 
features  of 
options  to  further  verify  identity, 
invoicing services, etc. 

Availability of a review and feedback 
system on other peers that is visible 
to  the  community,  e.g.  via  a  star-
based  rating  mechanism,  written 
feedback, etc. 

Systems  which  reward  peers  for 
good  performance 
through 
profile badges and special ratings 

i.e. 

Transaction 

Terms 
Conditions 

& 

T&Cs - platform use 

T&Cs 
services. 

for  using 

the  platform’s 

T&C - P2P interactions32  

T&Cs  governing,  in  part  or  in  full, 
the interaction between peers. 

32  T&Cs  for  P2P  interactions  range  from  simple  guidelines  on  keeping  the  transaction  within  the  law  (e.g. 
provide truthful information) to setting contractual conditions like cancellation policies or rules of behaviour 
(e.g.  TaskRabbit  has  a  set  of  marketplace  guidelines  in  place  to  adjust  peer  provider  services  to  their 
standards). 

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Stage  of  the 
transaction 

Service type 

Service description 

Mechanisms  affecting  the  pricing  of 
goods/services:  imposing  a  certain 
price/price  range/maximum  price, 
providing price setting tips or setting 
prices automatically. 

Availability  of  payment  methods  for 
peers to complete their transactions, 
including  management  of  payment 
by platforms and escrow services 

Monitoring of user activity to ensure 
compliance with the platform’s rules 
and/or T&Cs. 

Insurance 
mandatory  or  optional, 
transaction. 

services, 

either 
the 

to 

Availability of mechanisms to handle 
peer  complaints,  e.g.  via  email, 
ticketing service, hotline, etc. 

Monitoring of the goods and services 
listed  on  the  platform  and  active 
engagement 
and 
detecting 
removing the fraudulent ones. 

in 

Platforms  on  behalf  of  relevant 
authorities  collected  relevant  taxes 
from peer provider 

Price guidance/imposition 

Payment services33. 

User monitoring 

Insurance/guarantees 

Complaints handling 

Post-
transaction 

Compliance monitoring and action 

Tax collection 

Tax 
assistance 

Source: VVA 

Assistance  with 
declarations 

tax 

Platforms assist with tax declaration 
which  then  peers  can  report  to  the 
relevant authorities34 

Figure 3 illustrates the prevalence of the above platform services across the sample of 
485 P2P platforms in all EU Member States and Norway. The results show that there is 
a great diversity in the range of services offered across P2P marketplaces in Europe.  

33 This covers only payments facilitated or managed by platforms, so payments outside the platform (e.g. in 
cash) are not covered. 
34 Services such as tax collection and assistance with tax declarations originate from the case study analysis 
under Task 4 and they were not included in the Task1 data collection. 

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Figure 3: Prevalence of different services in selected P2P platforms 

Source: VVA analysis of 485 platforms, see Task 1 report (Section 1.3) regarding platform selection criteria 
and definition of each of the services included in the research. 

Figure  3  further  indicates  that  the  focus  of  P2P  platform  services  is  on  the  pre-
transaction  phase,  as  confirmed  by  the  literature  and  by  stakeholders  attending  the 
first  workshop  held  in  the  scope  of  this  study.  According  to  Brescia  (2016),  whereas 
conventional businesses generate trust among consumers via explicitly complying with 
governmental  regulations,  platforms  must  seek  other  ways  of  creating  trust35, 
including,  as  Slee  (2013)36  or  Lobel  (2016)37  suggest,  through  reputational  systems 
such as reviews, ratings and recommendations.  

The  results also show  that  a  significant  number of  platforms do not offer  certain  key 
services to ensure transparent, fair and safe transactions for consumers. 

  At  the  pre-transaction  phase  only  about  half  of  the  platforms  actively  seek  to 
promote  trust  through  safety  information  or  peer  review  systems.  Even  fewer 
platforms actively promote safer transactions through checking peer identity or 
other user information (25%), or running criminal checks (1%). 
In  terms  of  transaction  services:  the  vast  majority  (86%)  of  P2P  platforms 
have T&Cs determining the relationship between themselves and the peers, but 
only  one  third  (35%)  also  have  specific  T&Cs  for  P2P  interactions.  More  than 
half  (55%)  facilitate  or  manage  payments  themselves,  and  22%  of  all 
platforms  in  the  sample  suggest  or  impose  prices  for  the  P2P  transactions38. 

 

things  about 

35 Brescia, 2016 
36  Slee,  T.  (2013).  Some  obvious 
http://tomslee.net/2013/09/some-obvious-things-about-internet-reputation-systems.html 
37 Lobel, O. (2016). The Law of the Platform. Univ. of San Diego, Legal Studies Research Paper Series, Mar. 
2016, available at http://ssrn.com/abstract = 2742380. 
38 For instance, AirBnB provides a “smart pricing” option whereby peer providers can choose to allow the platform 
to set a price, within a range indicated by the peer, in function of supply and the demand. Transport platforms such 
as BlaBlaCar or Uber also give pricing guidance: Uber sets by default a maximum recommended price, which 
drivers can adjust downwards through the mobile app. BlaBlaCar computes a price per kilometre based on fuel and 
34 

reputation  systems.  Available  at: 

internet 

1%20%25%45%48%52%59%22%35%55%86%24%27%30%53%0%20%40%60%80%100%Criminal(cid:9)records(cid:9)checkAdd-on(cid:9)servicesIdentity(cid:9)verificationInfo(cid:9)on(cid:9)rules&taxesAdvice/rules(cid:9)on(cid:9)safetyPeer(cid:9)review&reputation(cid:9)systemDemand&supply(cid:9)matchingPrice(cid:9)guidance/impositionT&C(cid:9)-P2P(cid:9)interactionsPayment(cid:9)servicesT&Cs(cid:9)-platform(cid:9)useInsuranceCompliance(cid:9)monitoring(cid:9)&(cid:9)actionUser(cid:9)monitoringComplaints(cid:9)handling(cid:9)(cid:9)PRE-TRANSACTION(cid:9)SERVICESTRANSACTION(cid:9)SERVICESPOST-TRANSACTION(cid:9)SERVICESPercentage(cid:9)of(cid:9)platforms 
 
 
                                                 
Exploratory study of consumer issues in online peer-to-peer platform markets –  
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Credit cards are the most widely-used payment method - available on 70% of 
platforms  offering  a  payment  service,  followed  by  debit  cards  (44%)  and 
PayPal (37%). Management of payments by the platform itself includes escrow 
services, meaning that the platform holds the payment from the peer consumer 
until it is confirmed that the transaction is completed successfully.39 

  At  the  post-transaction  stage:  more  than  half  have  a  complaint  handling 
system  (53%)  and  one  in  four  platforms  offer  insurance  (24%).  Less  than  a 
third  of  platforms  engage  in  user  monitoring  (30%)  or  compliance  monitoring 
(27%).  

There are notable differences between platform services by sector:   

  There  are  differences  in  how  platforms  in  each  market  try  to  build  trust.  For 
instance,  sharing/hiring  rides  platforms  tend  to  foster  trust  in  the  pre-
transaction phase via advice/rules on safety (68%), peer review and reputation 
systems (60%), information on rules and taxes (52%) or user data and identity 
verification  mechanisms  (36%).  The  strategy  adopted  by  (re)sale  of  goods 
platforms  to  build  trust  relies  more  on  post-transaction  services  like  user 
monitoring or anti-fraud monitoring and action. 

  User  data  and  identity  verification  is  more  frequent  and  systematic  in  the 
sharing/hiring  ride  sector  than  in  the  other  sectors:  in  the  accommodation 
sector only 21% of platforms perform some form of check. The lack of certainty 
regarding  other  peers’  identity  may  create  safety  issues  or  complications  in 
case something goes wrong with the transaction.  

  Platforms facilitating the sharing/renting of accommodation and sharing/renting 
of goods provide fewer pre-transaction trust-building services like peer review 
systems or identity verification than platforms engaged in sharing/hiring rides, 
odd jobs and (re)sale of goods.  

  One third of platforms set terms for P2P interactions and/or P2P transactions; 
27%  of  platforms  in  the  (re)sale  of  goods  sector  do  so,  15%  of  the 
sharing/renting  accommodation  platforms  and  17%  of  the  sharing/renting  of 
goods platforms. 

  Post-transaction services: sharing/hiring rides platforms are more likely to offer 
insurance, while (re)sale of goods platforms engage more in monitoring of user 
behaviour and listings.  

 

In  the  post-transaction  phase,  platforms  do  not  systematically  monitor  users’ 
compliance with platform rules: only 30% of all platforms do so. This relatively 
low  level  of  compliance  monitoring  increases  the  risk  of  unfair  or  fraudulent 
activity. 

 

.  About  half  of  the  platforms  in  the  four  collaborative  sectors  offer  complaints 
handling and only about a quarter engage in user or compliance monitoring.  

  Monitoring  of  compliance  of  peers  with  platform  rules  varies  between  sectors: 
almost half of the (re)sale of goods platforms monitor peer behaviour, but only 
11% of platforms in the sharing/hiring rides sector do so.  

  A quarter of all platforms (24%) provide insurance to peers, either included in 
the  price  or  against  an  additional  charge.  Sharing/hiring  rides  platforms  are 
more likely to offer insurance than other platforms (31%)   

other costs, and allows the driver to revise it by 50% upwards or downwards, but not beyond. Peerby Go imposes 
prices for the renting of items, based on algorithms of supply and demand for such items. 
39  This  finding  results  from  the  case  study  analysis.  Escrow  services  were  not  included  in  Task  1  data 
collection. 

35 

 
 
                                                                                                                                                    
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Figure 4 : Pre-transaction services, divided by P2P market 

Source:  VVA  analysis  based  on  data  collected  from  the  websites  of  485  sharing  platforms  from  March  to 
December 2016 

In terms of platform accessibility, Figure 5 below shows that the availability of mobile 
apps  in  the  sample  of  485  platforms  ranges  from  21%  on  sharing  /  renting  of 
accommodation platforms, to 40% of (re) sale platforms and 42% of sharing/hiring of 
rides  platforms.  This  indicates  that  only  a  minority  of  P2P  transactions  occurs  via 
mobile apps, and a majority via websites. Across the sample, 32% of all P2P platforms 
have mobile apps. However, data on usage of app-based P2P platforms are not readily 
available.  

App  based  interfaces  raise  specific  consumer issues  such as small  displays,  ads,  lack 
of  pinch-zoom  functionality,  performance  or  poor  navigation40.  Indeed,  already  in 
2007,  the  OECD  raised  a  number  of  privacy  and  security  issues  in  relation  to  mobile 
commerce.  These  included,  but  were  not  limited  to  the  impact  of  location-based 
services,  provision  of  information  on  terms  and  conditions,  privacy  policies  or 
complaint  procedures  due  to  limited  capacity  of  the  screens  on  mobile  devices  and 
provision  of  secure  payment  scheme, 
to  prevent 
unauthorised  use41.  As  the  OECD  (2016)42  also  points  out,  when  mobile  devices  are 
used for e-commerce activities, consumers tend to make more rash decisions and they 
may fail to understand their rights and obligations. 

including  authentication, 

Insights 

40  Abramovich,  G.  (2017).  Study:  Smartphone  Traffic  Grows  Fast,  But  Revenue  Still  Lags  Desktop.  Adobe 
Digital 
http://www.cmo.com/adobe-digital-
insights/articles/2016/10/7/adi-mobile-retail-benchmark-2016.html#gs.0pR7NJI  
41 OECD (2007). Mobile Commerce. OECD Digital Economy Papers No. 124 . Available at: http://www.oecd-
ilibrary.org/docserver/download/231111848550.pdf?expires=1491394176&id=id&accname=guest&chec
ksum=16C6EAC3A47B15B1FD25AC62B6F51EA2  

CMO.com. 

Research. 

Available 

at: 

42 OECD (2016). Consumer Protection in E-Commerce. OECD Recommendation. Available at: 

http://www.oecd.org/sti/consumer/ECommerce-Recommendation-2016.pdf  

36 

 
 
 
                                                 
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Figure 5: Availability of mobile apps on P2P platforms, per sector of activity 

Source: VVA analysis of 485 platforms, see Task 1 report (Section 1.3) 

3.3  Peer usage of P2P platforms 

In the consumer survey carried out for this study, 77% of the online population in 10 
MS  indicated  that  they  had  used  at  least  one  online  P2P  platform  in  one  of  the  five 
sectors  of  activity  examined  during  last  12  months.  Most  of  the  23%  of  respondents 
who  had  not  used  such  a  platform,  said  they  might  do  so  in  the  future43.    These 
figures  are  higher  than  those  reported  in  other  studies  because  this  survey  includes 
(Re)Sale platforms44, in addition to collaborative or “sharing economy” P2P platforms. 
Concretely,  73%  of  all  survey  respondents  had  used  (Re)Sale  platforms,  while 
between 8% and 15 % had used one or more of the collaborative platforms. 

Table 5: Usage of online P2P platforms 

Used at least one platform 

Never used a P2P platform 

77% 

23% 

May use a P2P platform in the 
future 
17.3% 

Source: Task 2 survey results; Base: All respondents – including screen outs (N=14597) 

When  using  P2P  platforms,  most  survey  respondents  (72%)  had  acted  both  as  peer 
consumers and peer providers and most peer consumers and peer providers had used 
only one platform (respectively 78% and 79%). 

Not  all  survey  respondents  who  indicated  that  they  had  used  an  online  P2P  platform 
also  reported  how  much  they  spent  or  earned.  But  a  very  large  majority  (85%)  of 
those  who  said  they  used  platforms  did  report  at  least  some  spending  or  earnings 
from transactions (either as peer providers or peer consumers) on a P2P platform over 

43 The incident rates of usage are based on respondents’ usage of the 5 different types of P2P platforms. As 
such,  respondent  scan  be  both  counted  for  ‘used  at  least  one  platform’  and  ‘non-users  of  at  least  one 
platform who may use this platform in the future’. After all, respondents may be users of one platform type 
and an interested non-user for another platform type. This is not the case for ‘never used a P2P platform’. 
44  See  for  instance:  ING  International  Survey  (2015),  WHAT’S  MINE  IS  YOURS  –  FOR  A  PRICE.  RAPID 
GROWTH TIPPED FOR THE SHARING ECONOMY 

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the last 12 months45. 15% of respondents who had used at least one P2P platform in 
the  last  12  months  did  not  report  any  earnings  or  spending  in  transactions  on  these 
platforms  

This  means  that  with  respect  to  the  full  sample  of  internet  users  in  the  ten  EU 
countries,  in  total  65.4%  reported  at  least  some  earnings  or  spending  over  a  12-
month period on P2P platforms.  

Assuming  the  behaviour  of  the  average  respondent  in  the  10  MS  is  identical  to  the 
behaviour of the internet population in the EU as a whole  46, we can estimate that at 
least 65.4% of all EU internet users47 have engaged in monetary P2P transactions over 
the  past  12  months.  Out  of  a  total  population  of  366.6  million  people  aged  over  18 
across all 28 EU Member States48, there are approximately 292 million internet users. 
Therefore,  the  study  estimates  that  about  191  million  people  across  the  EU  have 
engaged  in  at  least  one  paid  P2P  transaction  in  the  last  12  months49  (see  Figure  6 
below). 

Figure  6:  Number  of  active  P2P  market  participants  in  the  total  population 
(aged 16-74), EU-28 extrapolated from EU-10 

Source: VVA analysis based on European Commission (2015). Digital Single Market Report (Provision of two 
online consumer surveys as support and evidence base to a Commission study: Identifying the main cross-
border obstacles to the Digital Single Market and where they matter most). 

Looking  further  into  the  penetration  of  online  P2P  markets,  the  survey  shows  that  a 
large  majority  of  the  online  population  of  all  ages  use  online  P2P  platforms.  Young 

45 The percentage is computed as the ratio between the total number of platform users (77% of 14,597 = 
11,240) and the share of respondents that spent or earned more than EUR 0 on P2P platforms over the past 
12 months (9,548). 
46  In  line  with  the  methodology  and  limitations  described  in  sub-section  3.4.1,  the  extrapolation  entails  a 
loss of data reliability. 
47  The  percentage  of  internet  users  is  EUROSTAT  data  taken  from  European  Commission  (2015).  Digital 
Single  Market  Report  (Provision  of  two  online  consumer  surveys  as  support  and  evidence  base  to  a 
Commission study: Identifying the main cross-border obstacles to the Digital Single Market and where they 
matter most). The data represents the incidence rate of those aged 16-74 who had used the internet in the 
past year. 
48  Data  on  EU  population  is  EUROSTAT  data  taken  from  European  Commission  2015  Digital  Single  Market 
Report  (Provision  of  two  online  consumer  surveys  as  support  and  evidence  base  to  a  Commission  study: 
Identifying the main cross-border obstacles to the Digital Single Market and where they matter most), page 
324, Table II.1. EU population refers to citizens aged 18+. 
49 The P2P market participants rate is calculated according to the method described in this section. Further 
methodological explanations are given in sub-section 3.4.1 

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people are most likely to engage, - over 80% of this age group have used at least one 
platform. But 75% of 35-54 olds and 56% of the over-55 age group also participate in 
the P2P economy50. Men (70.4%) are slightly more likely to use an online P2P platform 
than women (66.8%)51.  

Table 6: Engagement with online P2P platforms in 10 MS  

Engagement with 
online P2P platforms 
Used P2P platforms 
Did not use P2P 
platforms 
Source: Task 2 survey; Base: all peer consumers (N=8705) and peer providers (N=8498) 

18– 34 
year olds 
82,1% 

35 – 54 
year olds 
74,7% 

55+ year 
olds 
55,8% 

Women 

44,2% 

25,3% 

17,9% 

33,2% 

66,8% 

Men 

70,4% 

29,6% 

Because  of  large  differences  between  the  (Re)Sale  sector  and  the  collaborative 
sector52, it is important to look at the results for the different platform types. (Re)Sale 
of  goods  platforms  are  by  far  the  most  used  type  of  P2P  platform  (72.9%),  while 
collaborative platforms are used by fewer respondents. 7.7% of respondents indicated 
that they had used a platform for odd jobs and between 12%-15% had used platforms 
for renting or sharing of goods, accommodation or rides. Also, most respondents had 
heard  about  (Re)Sale  of  goods  platforms  (only  3.2%  had  never  heard  about  them), 
while  this  awareness  was  relatively  lower  for  the  collaborative  platforms  (between 
22.9%  and  47.4%  of  respondents  had  never  heard  about  them).  It  is  notable  that 
among  collaborative  platforms,  sharing/renting  accommodation  and  sharing/hiring 
rides  platforms  are  used  and  known  most  often.  The  figures  for  accommodation, 
sharing/hiring rides and odd jobs are comparable to those found in other studies53. 

Table 7: Differences in use of online P2P platforms, by sector, 10 MS 

Sharing/hiring 
rides 

3.2% 

44.1% 

(Re)sale 
of goods 

Sharing/renting 
Accommodation 

Sharing/renting 
goods 

Usage of 
categories 
of online 
P2P 
platforms 
Never 
heard of it 
Know but 
have not 
used 
Have used 
Have not 
used but 
may in the 
next 12 
months 
Source: Task 2 survey; Base: all respondents – including screen outs (N=14597) 

12.1% 

14.4% 

72.9% 

18.6% 

28.9% 

49.6% 

36.5% 

5.1% 

7.3% 

7.2% 

22.9% 

54.9% 

14.8% 

7.4% 

Odd 
jobs 

47.4% 

37.6% 

7.7% 

7.4% 

Looking  at  frequency  of  use  over  the  past  12  months  shows  that  about  half  of  peer 
consumers and peer providers that are active on the investigated platforms use them 
weekly or monthly and these figures are roughly the same for the (re)sale sector and 
the  collaborative  sector.  There  are  however,  interesting  differences  within  and 
between sectors of activity:  

50 See Annex 2 of Task 2 report. 
51 See Annex 2 of Task 2 report. 
52  In  line  with  the  European  Commission’s  (2016)52  definition  of  “collaborative  economy”,  which  indicates 
that  “Collaborative  economy  transactions  generally  do  not  involve  a  change  of  ownership”,  the  term 
“collaborative  sector”  in  this  report  refers  to  sharing/hiring  of  rides,  sharing/renting  accommodation,  odd 
jobs and sharing/renting of goods. 
53  See  for  instance:  ING  International  Survey  (2015),  WHAT’S  MINE  IS  YOURS  –  FOR  A  PRICE.  RAPID 
GROWTH TIPPED FOR THE SHARING ECONOMY  

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 

(Re)Sale  of  Goods  platforms  are  used  by  around  half  of  peer  consumers 
(43.8%) and peer providers (46.6%) either every week or once a month.  

  Both  peer  consumers  and  peer  providers  who  are  active  on  Odd  Jobs  and 
Sharing/Renting Goods platforms tend to use them on a regular basis: around 
a quarter of users of these platforms use them every week and a further third 
at least once a month.  

  Peer  consumers  use  Sharing/Renting  Accommodation  and  Sharing/Hiring  Ride 
platforms with less regularity. They are more likely to be used once a month or 
a couple of times per year (respectively 63.5% and 57.7%). 

  A  substantial  proportion  of  peer  providers  in  the  accommodation  sector  rent 
out accommodation on a regular basis, 15.9% once a week and 20.6 % once a 
month. 

 

In the Ridesharing/hiring sector 16% of peer providers say they gave rides at 
least once a week, but most of them do so less regularly. 

  About a fifth of peer providers used the platform on a weekly basis to perform 

odd jobs.   

Table 8: Frequency of active use of online P2P platforms – Sector breakdown 
(Peer consumers)  

Frequency of use – 
Users  

(Re)sale of goods 
Sharing/renting 
Goods 
Sharing/renting 
accommodation 
Sharing/hiring 
rides 
Odd jobs 

Every week 

Once a month 

14.1% 
26% 

29.7% 
32.9% 

A couple of 
times per 
year 
46% 
28.6% 

Once per year 

10.2% 
12.5% 

11.4% 

15% 

34.4% 

39.1% 

13.1% 

22.5% 

46.1% 

18.3% 

21.2% 

27.2% 

33.3% 

18.3% 

Source: Task 2 report, Base: Peer consumers (N=8705) 

Table 9: Frequency of active use of online P2P platforms – Sector breakdown 
(Peer Providers) 

Frequency of use – 
Providers 

Every week 

Once a month 

26.6% 
29.8% 

19.8% 
24.4% 

(Re)sale of goods 
Sharing/renting 
Goods 
Sharing/renting 
accommodation 
Sharing/hiring 
rides 
Odd jobs 
30.3% 
Source: Task 2 report,, Base: Peer providers (N=8498) 

15.9% 

20.6% 

26.4% 

21.7% 

16% 

A couple of 
times per 
year 
42.7% 
31.6% 

Once per year 

10.9% 
14.1% 

35.7% 

27.8% 

44.5% 

13.2% 

32.9% 

15.1% 

Finally, peer consumers and providers may use more than one platform. The findings 
of  this  survey  show  that  a  large  majority  use  only  one  platform  (78.8%  for  peer 
consumers  and  78.4%  for  peer  providers),  while  21.6%  of  peer  consumers  on  P2P 
platforms and 21.2% of providers use multiple platforms. 

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Table 10: Use of single or multiple platforms (consumers and providers) 

Using 1 platform 

Using multiple platforms 

Peer consumers 

Peer providers 

78.8% 

78.4% 

21.2% 

21.6% 

Base: All peer consumers (N=8705) and peer providers (N=8498) 

3.4  Economic significance of P2P online platform markets 

The economic significance of peer to peer markets within the scope of this study can 
be  estimated  in  terms  of  peer  user  expenditure  on  transactions  facilitated  by  P2P 
platforms, revenues for peer providers as a result of these transactions, and revenues 
of platforms and third parties paid through the platform.  

3.4.1  Methodology  

EU-level estimates of peer expenditure and peer revenues are calculated on the basis 
of the Task 2 consumer survey run in 10 MS by sector of activity. The survey targeted 
consumers;  respondents  were  not  asked  to  declare  if  they  were  professional  or  non-
professional peer providers.  

The method for estimating total expenditure and revenue used in this study  is based 
on  the  median  peer  expenditure/revenue  in  each  of  the  five  economic  sectors 
considered.  This is  because  the distribution  of  the  data on  expenditure  and  revenues 
in the survey sample is skewed towards the extremes. For such skewed distributions, 
the median value is a better measure of the overall tendency than the average, or the 
mean. The median represents the value that splits the sample into two equal halves: 
50%  of  peer  consumers  spend  less  than  the  median  and  50%  of  peer  consumers 
spend  more  than  the  median.  Thus,  the  median  provides  a  more  conservative 
estimate of the results than the mean (see also section 3.3.2).  

The  average  and  median  values  used 
total 
revenues/expenditures  per  sector  by  active  users  over  the  past  12  months.  They  do 
not distinguish between expenditure on individual platforms.54  

this  calculation  refer 

to 

in 

For  each  economic  sector,  total  peer  expenditure  is  calculated  using  the  following 
formula. The same formula is applied for peer revenues: 

𝑆𝐸𝐶(𝐸𝑥𝑝𝑡𝑜𝑡𝑎𝑙) =   𝑀𝑆(𝐼𝑛𝑡𝑢𝑠𝑒𝑟𝑠) ∗   𝐸𝑥𝑝𝑝𝑒𝑒𝑟 ∗  𝑇𝑜𝑡(𝑃2𝑃𝑢𝑠𝑒𝑟𝑠) ∗  𝑆𝐸𝐶(𝑃2𝑃𝑐𝑜𝑛𝑠𝑢𝑚𝑒𝑟𝑠)  

  SEC(Exptotal) = the total peer expenditure in the given sector; 

  MS(Intusers)  =  the  total  number  of  internet  users  in  the  EU,  based  on  the 
EUROSTAT  data  taken  from  the  European  Commission’s  (2015)  Digital  Single 
Market report; 

  Exppeer  =  the  median  peer  expenditure  recorded  in  the  10  MS  in  which  the 

survey ran; 

54  Note  differences  in  averages  between  this  report  and  the  Task  2  report  reflect  a  different  focus:  the 
figures here refer to average total spending per sector (irrespective of the number of platforms). The figures 
in the Task 2 report are based on the average spend per platform in each sector. 

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  Tot(P2Pusers) = the percentage of total respondents engaged in P2P transactions 
who  reported  their  spending  (or  earnings),  based  on  the  10  MS  in  which  the 
survey ran. The percentage is 65.41%; 

  SEC(P2Pconsumers)  =  the  percentage  of  peer  consumers  who  reported  their 
spending  in  each  sector  under  study,  out  of  the  total  number  of  active  users 
who reported their spending across all P2P platforms (Tot(P2Pusers)).55 

The  EU-level  estimate  for  total  peer  expenditure  is  compiled  by  summing  up  each 
sector’s estimated peer expenditure. The same approach is used to estimate EU-level 
total peer revenues. 

Box 1: Methodological limitations 

There are several limitations with the models used to calculate economic significance of P2P markets. 

First, the values indicated in this section are estimates based on the consumer survey conducted in 10 MS 
on  internet  users  age  18  and  above  as  part  of  this  study.  The  results  recorded  in  the  10  MS  have  been 
extrapolated to the EU as a whole.  

Second, only EU citizens aged 18 or over were considered for estimating the EU population, and EU citizens 
aged 16-74 for the incidence of internet use. Peers younger than 16 are not considered in the study 

Third,  this study relies on median, rather than average values for peer revenues and  peer expenditure to 
calculate a EU-level estimate for peer revenues and expenditure. Using average values would lead to higher 
estimates of the economic size of P2P markets. 

Fourth,  respondents  may  have  interpreted  the  question  about  "money  received  through  the  platform" 
differently. In particular, some peer providers may have deducted costs from the money they report to have 
"received through the platform", thus reporting only real or net earnings. Such costs may be higher or lower 
depending on the sector, or the type service provided.56  

3.4.2  Peer consumer expenditure 

Figure  7  shows  the  mean  and  median  values  of  peer  expenditure  in  each  of  the  five 
markets under study. The results point to two important conclusions. First, under both 
indicators,  peer  consumers  spend  the  most  in  the  sharing/renting  accommodation 
sector, and the least in the sharing/hiring rides sector.  

Second, the spread between mean and median is considerable: the mean ranges from 
3.09  times  the  median  in  the  odd  jobs  sector  to  2.06  times  the  median  in  the 
sharing/renting  accommodation  sector.  Second,  under  both 
indicators,  peer 
consumers spend the most in the sharing/renting accommodation sector, and the least 
in the sharing/hiring rides sector.  

55  For  peer  consumers,  these  figures  were:  Resale  of  goods:  62.14%;  sharing/renting  of  goods:  4.41%;  sharing/renting 
accommodation:  8.23%;  sharing/hiring  rides:  9.28%;  odd  jobs:  3.28%;  for  peer  providers,  these  figures  were:  resale  of  goods: 
56.41%;  sharing  /  renting  of  goods:  4.29%;  sharing  /  renting  accommodation:  5.39%;  sharing  /  hiring  of  rides:  8.31%  and  odd 
jobs: 3.47%  
56  Car-sharing  platforms  allow  peers  to  lend  cars  to  other  peers  (e.g.  HiyaCar,  EasyCar  Club),  while  ride-
sharing platforms allow peers to share the same ride between them (e.g. BlaBlaCar, UberPop, etc). On car-
sharing  platforms  like  Easycar,  the  money  received  by  peer  providers  excludes  fuel  consumption,  which  is 
directly paid by the peer consumer who uses the car. On ride-sharing platforms that act on a cost sharing 
basis,  such  as  BlaBlaCar,  the  money  received  by  peer  providers  is  a  capped  percentage  of  the  estimated 
cost of the trip.On ride-hiring platforms like Uber, the money received by the peer provider is assumed to 
cover part of the car’s running costs (e.g. fuel, insurance) as well as to compensate for the drivers’ time. 

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Figure 7: Mean and median P2P consumer expenditure in the last 12 months, 
per sector in the 10 MS under study, in EUR 

€ 0 

€ 200 

€ 400 

€ 600 

€ 800 

€ 1.000 

EXPENDITURE 

(Re)sale goods

Consumer durables

Transport

55 

Accommodation

150 

150 

156 

Odd jobs

166 

406 

384 

420 

514 

Mean Median

866 

Source: VVA analysis of Task 2 survey data; Note differences in the averages between this diagram and the 
Task  2  report  reflect  a  different  focus:  the  above  diagram  shows  average  total  spending  per  sector 
(irrespective of the number of platforms). Figures in the Task 2 report are based on the average spend per 
platform in each sector. 

The  results  presented  in  Figure  7  are  in  line  with  similar  results  obtained  by  ING 
(2015)57. Although using a different methodology, a PwC study (2015) also found that 
the sharing/renting accommodation sector had, by a considerable margin, the largest 
P2P transaction value in 201558. 

The  expenditure  values  presented  in  Figure  7  can  be  extrapolated  to  EU-level  to 
compute  an  estimate  of  total  peer  expenditure  in  the  five  P2P  markets  under  study. 
Based  on  median  expenditure59,  total  expenditure  by  peer  consumers  in  the  EU  P2P 
economy in the five sectors examined is estimated at EUR 27.9 billion.  

Figure  8  visualises  the  size  of  peer  consumer  expenditure  in  each  EU  MS.60  The 
calculation method adopted for total peer expenditure assumes that the main variable 
across MS is their active internet population, while the percentage of peer consumers 
involved in P2P transactions in each of the five sectors is assumed to be overall similar 
in all MS and equal to the average derived from the survey responses received in the 
10 MS under study.  

57 ING (2015). ING International Survey. Mobile Banking, New Technologies and Financial Behaviour. Available at: 
https://www.ezonomics.com/ing_international_surveys/mobile_banking_2015/  
58 PwC (2016). Assessing the size and presence of the collaborative economy in Europe.  
59 If we had considered mean expenditure, total expenditure by peer consumers in the EU P2P markets is 
estimated at EUR 71.67 Billion. 
60 The overall figures for total spending by peers across all P2P sectors were aggregated and produced an EU-level 
figure of EUR 27.9 billion. To map this figure, this study multiplied the median user expenditure with the 
percentage of sharing economy users at EU level times the internet population of each Member State. Therefore, 
the proportions assigned to each Member State are solely based on their number of internet users, and not on the 
actual spending/earning patterns recorded through the study’s survey. 

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Figure  8:  Total  estimated  yearly  spending  by  peer  consumers  on  P2P 
platforms, by EU Member State. 

Source: VVA analysis based on Task 2 survey data  

Country-specific estimated annual peer consumer expenditure is reported in Table 11. 
The  differences  between  countries  reflect  the  Member States  population  size  and  the 
incidence rate of internet use in each country. In the Netherlands, where 94 % of the 
population  uses  the  internet,  peer  consumer  expenditure  is  higher  than  in  more 
populous countries like Romania, where only 59% of the population uses the internet.  

Table 11: Total estimated annual peer consumer spending in EU28 MS 

Country 

TOTAL 

EU28 

Austria 

Belgium 

Bulgaria 

Cyprus 

Total yearly spending 
(EUR million) 

€ 27,905 

€ 497 

€ 651 

€ 310 

€ 43 

Czech Republic  € 614 

Germany 

€ 4,993 

Denmark 

Estonia 

Greece 

Spain 

€ 372 

€ 78 

€ 482 

€ 2,504 

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Country 

TOTAL 

Total yearly spending 
(EUR million) 

Finland 

France 

Croatia 

Hungary 

Ireland 

Italy 

€ 347 

€ 3,688 

€ 207 

€ 547 

€ 247 

€ 2,691 

Lithuania 

€ 149 

Luxembourg 

€ 36 

Latvia 

Malta 

€ 109 

€ 23 

Netherlands 

€ 1,089 

Poland 

Portugal 

Romania 

Sweden 

Slovenia 

Slovakia 

UK 

€ 1,887 

€ 482 

€ 819 

€ 613 

€ 108 

€ 326 

€ 3,996 

Source: VVA analysis of Task 2 survey data 

At  sector  level,  using  the  same  model,  the  (re)sale  of  goods  sector  accounts  for  an 
estimated  EUR  17.8bn  in  peer  consumer  spending  per  year  (see  Figure  9).  Peers 
spend  2.7  times  more  in  P2P  transactions  in  the  (re)sale  sector  compared  to  the 
second-largest sector, the sharing/renting accommodation with 6.6. billion EUR annual 
expenditure.  

Expenditure  in  the  sharing/renting  accommodation  sector  is  more  than  five  times 
higher  than  for  sharing/renting  goods,  odd  jobs  and  ride  sharing/hiring,  where 
expenditure  is  estimated  at  between  1  and  1.3  billion  EUR.  Peers  spend  the  least  in 
the sharing/hiring rides sector, which is 17.8 times smaller than the (re)sale of goods 
sector61. 

61  Due  to  the  low  sample  size  considered  in  this  study’s  survey  only  across  10  Member  States,  it  was  not 
possible to disaggregate expenditure per sector in each MS. Such a disaggregation would need to be solely 
based, as Figure 8 is, on the different internet population in each MS, while keeping everything else equal 
across MS. 

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Figure  9:  Total  estimated  annual  peer  consumer  spending  in  P2P  online 
markets, per sector, EU-28 

Source:  VVA  analysis  of  Task  2  survey  data,  EC  (2015).  Provision  of  two  online  consumer  surveys  as 
support  and  evidence  base  to  a  Commission  study:  Identifying  the  main  cross-border  obstacles  to  the 
Digital Single Market and where they matter most. 

Considering only the sectors that are included in the European Commission’s (2016)62 
definition  of  the  “collaborative  economy”  (i.e.  excluding  the  (re)sale  sector),  the 
accommodation  sector  is  clearly  the  largest  collaborative  sector  in  terms  of 
expenditure and ride hiring and sharing the smallest (Figure 10). 

Figure  10:  Total  estimated  annual  peer  consumer  spending  in  P2P  markets, 
per sector (without (Re)sale of goods), EU-28 

Source:  VVA  analysis  of  Task  2  survey  data,  EC  (2015).  Provision  of  two  online  consumer  surveys  as 
support  and  evidence  base  to  a  Commission  study:  Identifying  the  main  cross-border  obstacles  to  the 
Digital Single Market and where they matter most. 

62 European Commission (2016). COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE 
COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS: A 
European agenda for the collaborative economy. COM (2016) 356 Final. 

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3.4.3  Peer provider revenue 

On the peer provider side, Figure 11 shows, first that sharing/renting accommodation 
is the sector where peers earn the most through P2P transactions, while earnings are 
lowest in the sharing/hiring rides sector. 

Second, like for peer expenditure, the figure shows a large spread between mean and 
median values. The mean is 3.68 times the median in the resale sector, and 2.38 the 
median in sharing/renting accommodation.  

Figure 11: Mean and median annual P2P provider revenue, per sector, EUR 

€ 0 

€ 200 

€ 400 

EXPENDITURE 
€ 600 

€ 800 

€ 1.000 

€ 1.200 

(Re)sale goods

Consumer durables

Transport

Accommodation

100 

100 

50 

179 

Odd jobs

115 

368 

295 

400 

380 

954 

Source: VVA analysis of Task 2 survey data 

Mean Median

The  differences  between  mean  and  median  reported  above  can  be  explained  by  the 
fact that a major part of expenditure (50 to 60%) and revenue (50 to 70%) is driven 
by a small share of very active peer consumers and peer providers. Indeed, more than 
half of the revenue and expenditure is generated by 10% of peers.  

Such skewed levels of peer revenues were also found in the ING (2015) survey, which 
reported an 8.3-fold difference between the mean (EUR 2,500) and median (EUR 300) 
peer revenue, and which found that that as much as 80% of revenue ends up in the 
hands  of  10%  of  peer providers63.  Comparing  the  same  sectors and  only  considering 
the providers who declared at least some earnings in the survey for this study, the top 
10% of peer providers earn 56% of all revenues.  

The  survey  data  do  not  support  assumptions  regarding  the  predominance  of  specific 
socio-demographic variables distinguishing P2P platforms users from internet users in 
general,  or  that  younger  peers  are  more  likely  to  regularly  provide  services  on  P2P 
platforms.  On  the  contrary,  35-54-year-olds  earn  and  spend  more  than  18-34-year-
olds  in  all  five  markets,  and  over  55-year  olds  earn  the  highest  revenues  on 
accommodation platforms.  

The more likely explanation for the concentration of revenues and expenditure among 
a  small  group  of  peers  is  that  certain  peers  are  much  more  frequently  active.  As 

63 ING International Survey (2015), WHAT’S MINE IS YOURS  – FOR A PRICE. RAPID GROWTH TIPPED FOR 
THE SHARING ECONOMY. 

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regards revenues, this may also mean that these peer providers might be acting more 
as professionals or businesses on P2P platforms. In particular, larger platforms such as 
eBay  or  AirBnB are  likely  to  attract  professional  providers  and  (small)  businesses.  In 
terms of sectoral breakdown, the results based on median values in Figure 11 on peer 
provider  revenues  are  consistent  with  those  in  Figure  7  on  peer  consumer 
expenditure:  the  sharing/renting  accommodation  is  the  sector  where  peer  providers 
receive  the  most  through  P2P  transactions,  followed  by  the  odd  jobs  sector.  The 
median  value  for  revenues  from  sharing/hiring  rides  is  the  lowest  among  the  five 
sectors. 

The  median  revenues values  presented above  can  be  extrapolated  to the  EU-level  to 
compute  an  estimate  of  total  peer  provider  revenues  in  the  five  P2P  markets  under 
study.  Based  on  median  revenues64,  total  revenues  by  peer  providers  in  the  EU  P2P 
economy in the five sectors examined is estimated at EUR 17.29 billion. The figure is 
computed by multiplying the median revenue for each sector with the total number of 
estimated  peer  providers  in  each  sector,  and  then  summing  up  the  five  sectors.  The 
results, disaggregated by sector, are illustrated in Figure 12 below.  

Figure  12:  Total  estimated  annual  peer  provider  revenue  in  the  P2P  online 
markets, per sector, EU-28 

Source:  VVA  analysis  of  Task  2  survey  data,  EC  (2015).  Provision  of  two  online  consumer  surveys  as 
support  and  evidence  base  to  a  Commission  study:  Identifying  the  main  cross-border  obstacles  to  the 
Digital Single Market and where they matter most. 

The  distribution  of  peer  provider  revenue  between  sectors  in  Figure  12  is  similar  to 
that for peer consumer expenditure illustrated in Figure 9. The proportions, however, 
are  not  the  same.  The  (re)sale  of  goods  sector,  by  far  the  largest  sector  for  P2P 
revenues,  is  estimated  (at  EUR  10.8  billion)  to  be  2.63  times  the  size  of  the 
sharing/renting accommodation sector.  

Revenue  in  sharing/renting  accommodation  (EUR  4.1  billion)  is  more  than  five  times 
higher than that for sharing/renting goods, odd jobs and ride sharing/hiring. The other 
three  sectors  are  similar  in  terms  of  peer  provider  revenues,  at  around  EUR  800 
million each.  

64 If we would have considered the average revenue, the total revenues by peer consumers in the EU sharing 
economy is estimated at EUR 56.04 Billion. 

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Figure  13  shows  the  same  revenue  data  for  the  sectors  defined  by  the  European 
Commission  as  part  of  the  collaborative  economy,  without  the  (re)sale  of  goods 
sector.  

Figure 13: Total estimated annual peer provider revenue in P2P markets, per 
sector (without (Re)sale of goods), EU-28 

Source:  VVA  analysis  of  Task  2  survey  data,  EC  (2015).  Provision  of  two  online  consumer  surveys  as 
support  and  evidence  base  to  a  Commission  study:  Identifying  the  main  cross-border  obstacles  to  the 
Digital Single Market and where they matter most 

3.4.4  Estimate of platform and other non-peer revenue  

Based  on  the  two  estimates  above  for  peer  expenditure  and  peer  revenues,  the 
difference  between  P2P  spending  and  P2P  revenue  is  EUR  10.61  billion  per  year,  of 
which EUR 3.57bn per year in the collaborative economy sectors (i.e. excluding resale 
of goods)65. As illustrated in Figure 14, this means that, on average, about 61 cents of 
every  euro  spent  by  peer  consumers  on  (re)sale  of  goods  platforms  reaches  peer 
providers,  and  between  61  and  65  cents  for odd  jobs,  accommodation  sharing/rental 
and  renting/sharing  of  goods.  In  contrast,  in  the  sharing/hiring  rides  sector  81  cents 
of every EUR goes to the provider66.  

65 This estimate is based on the total revenues/expenditure of peers in each economic sector. The average and 
median values refer to total revenues/expenditures per sector, and do not account for the average/median values 
per platform used. In addition, the model only considers peers that were involved in monetary transactions on P2P 
platforms in the previous 12 months. 
66 For the (re)sale goods sector, 60% of peer expenditure reaches peer providers, and the figures are similar for 
the renting/sharing goods (65%), sharing/renting accommodation (62%), and odd jobs (63%) 

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Figure 14: Comparison between revenues and expenditure (EUR Bn) 

Source:  VVA  analysis  of  Task  2  survey  data,  EC  (2015).  Provision  of  two  online  consumer  surveys  as 
support  and  evidence  base  to  a  Commission  study:  Identifying  the  main  cross-border  obstacles  to  the 
Digital Single Market and where they matter most. 

The  difference  between  peer  consumer  expenditure  and  peer  provider  revenue 
includes the revenue of the platform as well as any third-party fees, costs or charges 
included  in  the  price  peer  consumers  pay  to  the  platform  such  as  insurance  costs, 
credit  card  or  payment  costs,  tourist  taxes,  etc.  These  may  vary  across  platforms, 
between sectors and individual transactions. The size of the difference may also result 
from  misreporting  of  revenue  and  expenditure  in  the  survey  by  respondents,  and  in 
particular  under-reporting  by  peer  providers.  Nonetheless,  a  large  share  of  the 
estimated EUR 10.61 billion is likely to represent platform revenues.  

A  PwC  (2015)  study67  found  that  five  collaborative  economy  sectors68  had  facilitated 
EUR 28 billion worth of transactions and generated EUR 4 billion in platform revenues 
in  2015.  Thus,  the  total  estimate  of  EUR  3.57bn  in  platform  revenue  across  four 
collaborative sectors is very close to the PwC estimate. 

Both  the  PwC  study  and  the  present  report  find  that  online  P2P  platforms  generate 
significant revenues for themselves. From a consumer policy perspective, this confirms 
that  these  platforms  act  as  traders  and  responsible  for  the  services  they  deliver  to 
their users.  

To  sum  up,  the  current  estimates  show  a  large  gap  between  total  estimated  peer 
expenditure  and  total  estimated  peer  revenues  in  (re)sale  of  goods,  odd  jobs, 
accommodation  and  renting/sharing  of  goods  sectors,  and  to  a  lesser  extent  in  ride 
sharing/hiring.  A  considerable  portion  of  this  difference  consists  of  P2P  platform 

67 PwC (2016). Assessing the size and presence of the collaborative economy in Europe. 
68 P2P accommodation, P2P transportation, on-demand household services, on-demand professional services and 
collaborative finance. 

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revenues.  However,  further  research  would  be  necessary  to  disaggregate  "non-peer 
revenues" and develop a full understanding of the share accruing to platforms and any 
potential third parties, other cost elements as well as the impact of underreporting of 
peer provider revenue.   

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4  Business models of P2P platforms 

This section presents a typology of P2P platform business models based on the results 
of  the  research  carried  out  as  part  of  Tasks  1  and  4  of  this  study.  Before  presenting 
the detailed typology, it is worth keeping in mind three elements that have influenced 
this section. 

1.  This typology focuses on the business models of online P2P platforms, not the 

activities of the peer providers.69  

2.  It  should  be  kept  in  mind  that  one  of  the  main  ways  in  which  P2P  platforms 
create  value  and  differ  from  traditional  businesses  is  through  their  direct 
control of digital data about the nature and volume of both demand and supply. 
They use these data to facilitate (increase the number/volume of) transactions 
and earn revenue.  

As a result, platforms may, according to some authors, reduce both consumer 
surplus70 (i.e. by charging consumers a price that is close to their willingness to 
pay)  and  producer  surplus71  (i.e.  by  facilitating  competition  between  the 
peers),  with  the  resulting  benefits  (i.e.  an  increased  number  of  transactions) 
accruing to the platform itself in the form of transaction fees, additional service 
fees, and data reuse72.  

3.  As Table 12 shows, a business model describes the process by which the value 
created by an economic activity is monetised. The main value to be considered 
depends  –  to  some  extent  –  on  the  intended  use  of  the  business  model 
typology.73 In this case, the purpose of the typology is to inform the analysis of 
consumer  issues  in  P2P  markets.  In  particular,  the  typology  should  help  to 
establish the applicability of existing consumer law in different segments of the 
P2P  economy.  Hence  the  focus  should  be  on  the  value  that  the  platform 
provides to peer users.  

4.1  Monetisation models of P2P platforms  

The literature review identified the following monetisation models of online platforms: 

  Transaction  fees:  fees  charged  on  transactions  intermediated  by  the  P2P 

platform, to peer consumers and/or peer providers; 

  Subscription fees: fees charged on a periodical basis by the platform to peers 

for access to its services; 

69 Indeed, the consumer survey in Task 2 as well as the focus groups have found that (at least some) peers 
participate  in  the  sharing  economy  for  economic  reasons  and  the  way  in  which  they  choose  to  structure 
their engagement with this  market could be seen as a peer-level “business model”. This is clear  when the 
peer provider is classified as a business / trader (a number of relevant indicators for this determination have 
been identified in Task 5) but even individual peers could be seen to be operating different business models 
such  as  reducing  their  costs  (e.g.  ride  sharing)  or  supplementing  their  income  (e.g.  making  a  profit  by 
renting out a second home).   
70  consumer  surplus  is  defined  as  the  difference  between  the  total  amount  that  consumers  are  willing  and 
able to pay for a good or service (indicated by the demand curve) and the total amount that they actually 
do pay (i.e. the market price). 
71 Producer surplus is measured as the difference between what producers are willing and able to supply a 
good or service for and the price they actually receive. 
72 See for instance this study on the “Platforms-based economy and economic rent”, available at 
 https://medium.com/@fred_marty/platforms-based-economy-and-economic-rent-6927120be22e 
73 For instance, if this study were interested in the environmental impact of P2P markets, then the business 
model analysis should consider the extent to which P2P platforms facilitate the extension of the useful life of 
an asset, or intensification of their use 

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  Add-on  services  fees:  fees  charged  for  optional  add-on  services  by  the 
platform  outside  the  transaction,  or  on  top  of  the  transaction  fees,  such  as 
promoted  listings,  professional  photographs,  verification  of  identity,  delivery, 
insurance, etc.; 

  Advertising:  revenue  generated  through  advertising  third-party  content  on 

the platform through banners, native advertising, etc.; 

  Data  use/reuse:  revenue  generated  through  sharing  or  selling  peer  data  to 

third parties74; 

  Other:  other  revenue  generation  such  as  cancellation  fees,  consumer  hotline 

fees, B2B services, etc. 

The  screening  of  485  platforms  shows  that  advertising  is  the  most  prevalent 
monetisation model, used by 53% of platforms; 48% use and reuse data to generate 
income,  a  third  of  platforms  (34%)  use  transaction  fees,  21%  subscription  fees,  and 
12% add-on services fees. A majority of platforms use a combination of strategies to 
generate  revenue.  Over  half  of  the  platforms  use  advertising  in  combination  with 
subscription  fees  (51%),  add-on  service  fees  (61%)  or  data  use/reuse  (64%).  Data 
use/reuse is also usually combined with a second monetisation model.  

Between  P2P  sectors,  there  are  differences  in  the  prevalence  of  monetisation 
strategies: Most (re)sale of goods platforms (80%) use advertising or data use/reuse 
(60%)  as  a  monetisation  strategy.  The  sharing/hiring  rides  market  features  the 
greatest diversity of monetisation models. 

By  linking  the  types  of  services  (described  in  Section  3.1)  with  the  different 
monetisation  models  above,  three  ways  in  which  peer  to  peer  platforms  create 
monetizable value can be identified:   

  Transaction / subscription-fee based models: such platforms offer a wide range 
of services with a focus on pre-transaction services. Their aim is to encourage a 
maximum  number  of  transactions  by  offering  a  wide  range  of  well  diversified 
services, in function of their level of maturity and financial solidity. 

  Advertising-based  models:  the  activity  of  these  platforms  focuses  more  on 
post-transaction  services  and  less  on  trust-building.  They  tend  to  adopt  more 
reactive,  rather  than  proactive  approaches  to  potential  user  issues  and 
problems. 

  Data use and re-use: platforms using this model offer a wide range of services 
and they often combine this model with either advertising, transaction fees or 
subscriptions fees. 

4.2 

 Core features in P2P business models 

Based  on  analysis  of  the  case  studies  (see  Task  4),  the  table  below  summarizes  the 
core  features  found  in  the  P2P  business  model  canvas  which  is  used  as  the  starting 
point for the further development of the business model typology in this report. 

74 Note that this study considers a platform uses data as a revenue source if its Terms and Conditions specify that 
it is allowed to share peer data with third parties for, among others, marketing purposes. It is not clear which 
platforms actually gain monetary value from peer data, but this study considers that all platforms which enable 
themselves to use peer data in this way in their Terms and Conditions end up doing so. 

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Table 12: Overview of common features in P2P business models 

Key Partners 

Key activities 

Value 
proposition 

Customer 
relationship 

Customer 
segments 

Community 
Investors 
Third party 
providers of 
additional services 
(e.g. payment 
processing, 
insurance, etc.)  

Cost structure 
Fixed costs 
Variable costs 
Advertising/PR 

Product 
development/Management 
Community building 
Customer service 

Key resources 

- community 
- technology 

Facilitate P2P 
transactions 
by  
Listing goods / 
services 
Generating 
trust among 
peers  
setting terms 
of P2P 
transactions 

Co-creation 
(e.g. user 
generated 
reviews) 
Automated 
services  
Channels 

Direct online: 
web & mobile 
apps 

Mass market 
products 
(sometimes 
geographically 
segmented)  
Multi-sided 
platform (targeting 
both providers and 
consumers) 

Revenue streams 
Transaction fee  
Service fees 
Subscription fees 
Data reuse  
Currency conversion fee  
Add-on services  
(external investment) 

Source: VVA analysis based on Business model canvas from Osterwalder A. & Pigneur Y. (2010): Business 
Model Generation: A Handbook for Visionaries, Game Changers, and Challengers  

The research in this study (primarily Task 1 and Task 4) has led to the identification of 
three  main  P2P  platform  business  models.  The  table  below  summarises  these  three 
business models with details on value creation, monetisation and their implications for 
platform control over the peer to peer transaction.  

The  level  of  platform  control  over  the  P2P  transaction  is  at  the  core  of  the  business 
model  categorisation.  The  rationale  behind  this  categorisation  is  that,  from  a 
consumer  policy  perspective,  greater  control  over  the  transaction  implies  or  creates 
the  impression  of  greater  platform  responsibility  for  the  performance  of  the 
transaction, for pre-contractual and contractual information.  

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Table 13: Typology of business models 

Model 

Value provided by the platform to peers  

Main monetisation models 

Hosting of listings 

 

Platform publishes listings and user reviews (including 
e.g. premium listings, etc.)   

Actively managed transactions 

 

Platform actively facilitates trust and transactions 
among peers through e.g.  
  Active matching of demand and supply through 

search functions/filters and instant messaging 
system  

  Guidance for posting listings  
  User data checks (through email or social media) 
  Confirmation of user information through email and 
additional questions to prevent unauthorized access 
 
Pre-screening of identity data (before registration)  
  Verification of identity documents after registration  
  Monitoring of user activity and control over access 

to platform  

  Non-binding pricing guidance  
  Guidance for P2P interactions 
  Management of peer review and reputation system  
  Monitors peer reviews with the right to delete them 
  Add-on services (e.g. professional photographer) 

Platform governs transactions  

Platform sets contractual terms of the P2P transaction 

 
  Handling of complaints and refunds  
 

Insurance etc.  

  Add-on service fees  
  Data reuse 
  Advertising fees 

Transaction fees and/or  

 
  Subscription fees 
  Data reuse 

 
 

Transaction fees  
data (re)use  

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4.3  Model 1: Hosting of Listings  

The  first  model  concerns  platforms  which  limit  themselves  to  passively  matching 
peer  demand  and  peer  supply  by  publishing  listings  and  enabling  contact  and 
feedback between users by publishing peer-generated information.  

This  includes  pure  listing  sites  with  no  reviews  (e.g.  Gumtree),  but  also  sites  that 
publish  user  generated  reviews  of  the  peer,  or  of  the  good/service  to  be  transacted, 
alongside the listing. Most such platforms also offer simple search functions based on 
keywords which facilitate the matching.  They tend to monetise the value they create 
by  charging  for  advertising,  charging  fees  for  add-on  services  such  as  premium 
listings, and through data reuse, monetising user data shared with the platform. 

Examples  of  such  platforms  include:  Gumtree  (UK),  Subito  (IT),  OLX  (PL),  2dehands 
(BE), Kijiji (IT), LeBonCoin(FR).  

The  key  feature  of  this  model  from  the  perspective  of  this  study  is  that  platforms  in 
this  category  do  not  become  involved  in  the  peer  to  peer  transaction.  Rather 
they limit themselves to providing a matching service to peers. Thus, these platforms 
have no influence over the performance or quality of the peer to peer transaction. 

4.4  Model 2: Actively managed transactions 

The  second  model  is  characterised  by  the  active  facilitation  and  management  of 
the matching of demand and supply.  

These  platforms  go  beyond  the  provision  of  demand  and  supply  information.  They 
create  value  by  fostering  trust  among  peers  and  actively  manage  and  facilitate  the 
matching, with the objective to increase the number and/or volume of transactions.  

Peer trust is one of the main drivers of platform business and active management of 
trust  between  users  becomes  increasingly  important  for  economic  success  as 
platforms  scale  up  and  the  initial  “community”  feel  among  a  smaller  group  of  users 
becomes more difficult to maintain.  

Thus, platforms operating in line with this model put in place tools and procedures to 
encourage trust among peers and thereby facilitate a greater number of transactions. 
This  may  raise  expectations  among  users  about  the  reliability  or  the  quality  of  the 
performance of the peer to peer transaction.  

  Advanced  matching  tools  such  as  geolocation,  multi  filter  search  systems, 

ranking of search results, etc.; 

  Active  management  of  messaging  systems  for  exchanges  between  peers  and 

exchanges with the platform;   

  User 

information  checks  and  pre-screening  or  verification  of 

identity 

documents; 

  Monitoring of user activity; 

  Pricing guidance and recommendations; 

  Guidance for P2P interactions; 

  Management of peer review and reputation system; 

  Monitoring of peer review and reputation system; and 

  Provision of add-on services, such as optional add-on insurance.  

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Platforms  tend  to  monetise  the  value  they  create  in  this  type  of  transaction  through 
charging subscription or transaction fees and through data reuse. Most platforms that 
actively  manage  P2P  transactions  charge  transaction  fees;  they  may  also  charge  for 
add-on services like insurance, or featured listings. 

The  key  feature  of  this  model  from  the  perspective  of  this  study  is  that  platforms  in 
this category influence the peer to peer transaction but they do not control the 
conditions  under  which  the  actual  transaction  takes  place  (i.e.  the  P2P 
contractual aspects).  

4.5 

 Model 3: Platform governed peer transactions 

The third model concerns platforms which explicitly set one or more of the contractual 
terms  of  the  peer  to  peer  transaction,  and  exercise  control  over  the  performance  of 
the transaction.  

The  key  feature  of  this  model  is  that  these  platforms  restrict  the  ability  of  peers  to 
decide contract terms between them, and give the impression explicitly or implicitly 
that  they  assume  (partial)  responsibility  for  the  performance,  of  the 
transaction.  Thus,  platform  control  over  the  P2P  transaction  is  at  the  core  of  these 
business  models.    Greater  control  over  the  transaction  implies  greater  platform 
responsibility for the performance and quality of the transaction.  

In  practice,  this  type  of  model  is  mostly  limited  to  larger  platforms  which  have  the 
human, economic and technological resources to develop, monitor and enforce peer to 
peer contracts. For instance, platforms with the following features would fall into this 
category: 

  Setting  terms  and  conditions  for  P2P  transactions,  by  setting  rules  for  P2P 

interactions, or rules and fees for cancellations, and rules for refunds; 

  Price setting: (optional) automated price setting or setting a maximum price.  

  Management of payments: these platforms receive and hold payments of peer 
consumers, and monitor the success of the P2P transaction before paying peer 
providers; they also frequently retain fess in case of cancellations 

  Management  of  complaints  and  refunds:  these  platforms  actively  intervene  in 
case  of  a  complaint,  stimulating  resolution  of  disputes  between  peers  or 
resolving disputes themselves through refunds or withholding payment  

 

Insurance  provided  as  part  of  the  transaction  fee:  these  platforms  provide 
some  form  of  insurance  against  damages  mostly  as  additional  coverage  for 
peer providers. 

Platforms  tend  to  monetise  the  value  they  create  in  this  type  of  transaction  through 
transaction  fees  and  through  data  reuse.  Most  platforms  in  this  category  charge 
transaction fees.  

4.6  The business model typology and the case study platforms 

It  is  important  to  note  that  a  single  platform  can  fit  into  more  than  one  business 
model if it offers several options of services to peers, for example, for setting prices or 
insurance.  

In fact, the business models are to some extent “incremental”: platforms that fall into 
the  second  category  (Active  Management)  also  perform  a  matching  service  and 
platforms  that  fall  into  the  third  category  (Platform  governed  peer  transactions)  will 
have most of the services or features of the other two. 

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Generally,  as  platforms  develop  a  larger  user  base,  there  is  an  evolution  of  platform 
business  models  over  time  from  the  simpler  (listings)  model  to  the  more  complex 
models  of  active  management  and  governing  the  terms  of  the  peer  to  peer 
transaction, and offering a wider array of services to its users. 

Table  14  maps  the  features  of  the  case  study  platforms  onto  the  three  business 
models  identified  in  this  section  (see  Task  4  case  study  report  for  further  details  on 
each case study platform). 

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Table 14 : Mapping of case study platforms onto the business model typology  

Platforms 
Airbnb 

Active management  
 

Active matching of demand and supply through search functions/filters and 
instant messaging system  

User information checks (through email or social media) 

  Guidance for posting listings  
 
  Optional pre-screening through verification of identity documents  
  Monitors user activity and controls access to platform  
 
Non-binding pricing guidance  
  Guidance for P2P interactions 
  Management of peer review and reputation system (ratings and badge) 
  Monitors peer reviews with the right to delete them 
 

Add-on services (professional photographer) 

BlaBlaCar 

 

Active matching of demand and supply through search functions/filters and 
instant messaging system  

  Guidance for posting listings  
 
  Optional pre-screening through verification of identity documents (France and 

User information checks (through email or social media) 

the UK only) 

  Monitors user activity and control over access to platform  
 
Non-binding pricing guidance 
  Guidance for P2P interactions 
  Management of peer review and reputation system (ratings and badge) 
  Monitors peer reviews with the right to delete them 

Platform governed transactions  
 
 
 
  Manages payments and monitors success of transaction before releasing 

Set standardised T&Cs that define interaction between peers 
Imposes rules and fees for cancellations  
Sets prices (optional "Smart Pricing")  

payment to peer provider 
  Governs security deposits  
  Manages complaints and refunds of P2P transactions 
 

Insurance for peer providers included as part of the transaction fee 

Set standardised T&Cs that define interaction between peers 
Imposes rules and fees for cancellations  
Sets prices (caps the price to prevent peers from making profit) 

 
 
 
  Manages payments and monitors success of transaction before releasing 

payment to peer provider75 

  Manages complaints and refunds of P2P transactions. 
 

Insurance for both peers included as part of the transaction fee 

easyCar Club 

 

 
 

Active matching of demand and supply through search functions/filters and 
instant messaging system 
User information checks (through email or social media) 
Pre-screening (verification of identity documents and criminal record check) of 
both peer providers and consumers 

  Guidance for P2P interactions 
  Management of peer review system and reputation system (ratings) 
  Monitors peer reviews with the right to delete them 

Imposes rules and fees for cancellations  
Sets prices (optional ‘market pricing’)  

 
 
  Manages payments and monitors success of transaction before releasing 

payment to peer provider 
  Governs security deposits 
  Manages charges for non-compliance with the platform’s rules 
  Manages complaints and refunds of P2P transactions  
 

Insurance for both peers included as part of the transaction fee 

eBay76 

 

Active  matching  of  demand  and  supply  through  search  functions/filters  and 

 

Set standardised T&Cs that define interaction between peers 

75 Only in countries where using transaction model, not in countries where cash for rides model applies – see case study for further details. 
76 The extent to which the platform is involved in the peers’ transaction depends on the listing format, the country and the nature of the item (high-value items). For example, 
classified ad listings are excluded from review/rating system and complaints and insurance services which do apply to auctions and “Buy It Now” listings. See case study for further 
details. 

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Platforms 

Active management  

instant messaging system  

  Guidance for posting listings  
 
 

User information checks (through email or social media) 
Confirmation of user information through email and additional questions to 
prevent unauthorized access 

  Monitors user activity and control over access to platform and listings  
 
Non-binding pricing guidance  
  Guidance for P2P interactions  
  Management of peer review and reputation systems (ratings and badge) 
  Monitors peer reviews with the right to delete them 
 

Add-on  services  such  as  automatic  bidding  for  peer  consumers;  international 
shipping  programme,  increased  visibility  and  selling  assistance  for  peer 
providers 

Nimber 

 

Active  matching  of  demand  and  supply  through  search  functions/filters  and 
instant messaging system 
User information checks (through email or social media or phone) 
 
 
Non-binding pricing guidance 
  Guidance for P2P interactions 
  Management of peer review and reputation system (ratings) 

Peerby77 

 

Active  matching  of  demand  and  supply  through  search  functions/filters  and 
instant messaging system  

User information checks (through email or social media); 

  Guidance for posting listings  
 
  Monitors user activity  
  Guidance for P2P interactions 
 

Add-on services on Peerby Go (pick-up and delivery) 

Platform governed transactions  
 
  Manages  payments  of  high-value  items  and  monitors  success  of  transaction 

Imposes rules for cancellation, if the provider is a private individual 

before releasing payment to peer provider 

  Manages complaints and returns, refunds, replacements and exchanges if the 

provider is a private individual 
Provisions that indicate the potential liability for P2P transactions in T&Cs 

 

  Manages  payments  and  monitors  success  of  transaction  before  releasing 

payment to peer provider  

  Manages complaints and refunds of P2P transactions   
 

Insurance as part of the transaction fee 

Sets standardised T&Cs that define interaction between peers (Peerby Classic) 
Imposes rules and fees for cancellation (Peerby Go) 
Imposes prices on all items (Peerby Go) 

 
 
 
  Manages complaints and refunds (refunds only on Peerby Go) 
 

Insurance78 for both peers as part of the transaction fee (Peerby Go)  

77 Peerby Classic is a for profit platform that currently does not charge for its services; Peerby Go charges a transaction fee and exchanges are against payment – see case study 
for further details  
78 Although, Peerby Go refers to ‘warranty’.  

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Platforms 
Uber Pool/Pop 

Wallapop 

Active management  
 

Active  matching  of  demand  and  supply  through  search  functions/filters  and 
instant messaging system  
User information checks (through email or social media) 
Pre-screening,  including  criminal  records  check  and  verification  of  identity 
documents of peer providers 

 
 

Platform governed transactions  
 
 
 
  Manages  payments  and  monitors  success  of  transaction  before  releasing 

Sets standardised T&Cs that define interaction between peers 
Imposes rules and fees for cancellations 
Sets maximum price per ride 

payment to peer provider 

  Monitors user activity and control over access to platform (suspension of user 

account in case of violations of the standards contained in T&Cs)  

  Manages complaints and refunds of P2P transactions 
 

Insurance for peer providers included as part of the transaction fee 

  Management of peer reputation system (ratings) 
  Monitors peer reputation system with the right to deactivate account with bad 

 

ratings  
Active matching of demand and supply through search functions/filters and/or 
instant messaging system 
  Guidance for posting listings  
 
  Monitors user activity and control access to platform  
  Guidance for P2P interactions 
  Management of peer review and reputation system (ratings) 
  Monitors peer reviews with the right to delete them 

User information checks (through email or social media) 

Wimdu 

 

Active  matching  of  demand  and  supply  through  search  functions/filters  and 
instant messaging system  

Imposes rules and fees for cancellations 

 
  Manages  payments  and  monitors  success  of  transaction  before  releasing 

  Guidance for posting listings  
 

User  information  checks  (through  email  or  social  media),  phone  calls  to  peer 
providers and occasional on-site visits 

  Monitors user activity  
 
Non-binding pricing guidance 
  Guidance for P2P interactions 
  Management of peer review system and reputation system (ratings) 
  Monitors peer reviews with the right to delete them 
 
 

Add-on services (professional photographers, translation service) 
Add-on insurance coverage for peer consumers 

payment to peer provider 
  Governs security deposits  
  Manages complaints and refunds of P2P transactions   
 

Insurance for peer providers included as part of the transaction fee  

Yoopies 

 

Active  matching  of  demand  and  supply  through  search  functions/filters  and 
instant messaging system 
User information checks (through email or social media) 

 
  Optional  pre-screening  (verification  of  identity  document  and  criminal  record 

check)  

Non-binding pricing guidance  

  Monitors user activity and control over access to platform  
 
  Guidance for P2P interactions (model contracts for P2P transactions) 
  Management of peer review and reputation system (ratings)  
  Monitors peer reviews with the right to delete them 

Source: VVA analysis of case studies (Task 4) 

 

Imposes rules and fees for cancellations 

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The  case  studies  did  not  include  platforms  that  operate  exclusively  under  the  first 
type of business model (i.e. hosting peer supply and demand). Most of the selected 
platforms  combine  elements  of  the  second  (active  management)  and  third 
(platform governed transactions) business models.  

All  case  study  platforms  show  features  of  the  second  business  model  to  actively 
facilitate  transactions  and  foster  trust.  The  most  frequent  platform  services  in  the 
2nd business model, are: 

  matching tools such as search and filter functions and messaging systems; 
  guidance  for  P2P  interactions,  notably  for  peer  providers  regarding  pricing 

and posting listings; 

  peer review or rating systems; and 
  monitoring user activity. 

The  most  frequent  features  of  the  third  business  model  governing  peer-to-peer 
transactions are:  

  management  of  payments  and  monitoring  the  success  of  the  transaction 

before releasing payments 
setting rules and fees for cancellation 
 
insurance as part of the transaction fee  
 
  management of complaints and refunds  

Half  of  the  case  study  platforms  are  also  involved  in  setting  prices  (AirBnb, 
BlaBlaCar, easyCar Club, Peerby Go and Uber) as an optional feature or by setting 
maximum  or  minimum  prices  (see  Section  6.2.1  in  this  report  and  Task  4  for 
further details).  

The  case  studies  show  that  for-profit  mature  platforms  charge  transaction  fees  of 
up  to  20-25%  of  the  listing  price  ranging  from  about  10%  on  easyCar  Club  and 
eBay to roughly 20% on Airbnb, Nimber, BlaBlaCar, Uber and 25% on Peerby Go. 
In addition, platforms may also charge fees for additional services.  

The  case  studies  also  show  that  as  platforms  grow  and  enlarge  their  user  base, 
they  start  offering  a  wider  range  of  services,  have  access  to  more  data  and  get 
more involved in regulating peer behaviour and interactions.  

Along with business models, platform monetisation strategies also evolve over time 
to  exploit  the  business  potential  of  an  increased  number  of  peer  users.  Thus,  as 
platforms mature, they tend to shift from free services and/or subscription fees to 
transaction fees.  

Overall,  case  study  platforms  development  strategies  are  characterised  by  the 
following features: 

  Set-up  cost  are  relatively 

low  and  they  mainly 

include  software 

 

development, Public Relations (PR) and community trust-building. 
Initially, platform services are offered for free or at cost, while the platform 
invests in building up its user-base as a critical mass of users is required to 
benefit from network effects. 

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  As  the  user  base  grows  beyond  the  initial  community  of  high-trust 
individuals, more trust building services are developed and the platform gets 
more  involved  in  'policing'  peer  behaviour  and  interactions  to  remedy 
problems with transactions and combat fraudulent behaviour.  

  Transaction  fees  are  charged  for  use  of  platform  services,  and  additional 
revenue streams are developed (fees for add-on services, cancellations etc.) 
  Data (re)use strategies become more sophisticated and valuable as the user 

community grows 

Most  case  study  platforms do not yet  appear  to  generate  profits,  but  reinvest  any 
earnings  in  market  expansion.  Once  the  platforms  grow  and  enlarge  their  user 
base,  consolidate  their  market  share  and  benefit  from  network  effects,  the  high 
level  of  automation  of  services  and  low  marginal  cost  of  additional  transactions  to 
the platform hold the promise of significant profits.  

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5  Peer experience, perceptions, expectations and problems 

in P2P markets  

This section describes the experience of peer consumers and peer providers in P2P 
markets. It reports the experience of 10.019 respondents who used one or more of 
the  P2P  platforms  under  examination  in  each  country.  A  significant  part  of  the 
sample  had  used  more  than  one  platform,  or  had  participated  both  as  a  peer 
consumer  and  as  a  peer  provider  on  the  same  platform.  These  respondents  could 
complete  the  questionnaire  twice,  i.e.  for  two  different  platforms,  or  from  the 
perspective  of  a  user  or  a  provider.  As  a  result  a  total  of  8705  peer  consumer 
experiences and 8498 peer provider experiences were collected. To further explore 
and  understand  the  behaviour  of  peers,  10  focus  groups  with  each  7  or  8  peer 
consumers  and  peer  providers  active  on  relevant  online  P2P  platforms  were 
organized in 10 cities in each of the countries79 included in the consumer survey – 
in total 78 peers.  

The detailed methodology for Task 2 survey and Task 3 focus groups is presented 
in Section 2 (with further details in the Task 2 and 3 reports). 

5.1  Levels of peer satisfaction  

A large majority of both peer consumers and providers who used the selected P2P 
platforms  over  the  last  12  months  are  satisfied  or  very  satisfied  with  their 
experiences.  More  than  three  quarter  of  P2P  users  are  satisfied  or  very  satisfied 
with P2P platforms, while only 4% to 5% are dissatisfied.  

Table 15: Satisfaction with overall experience using P2P platforms 

Satisfaction with 
overall experience 
using P2P platforms 

Very satisfied or   
Satisfied 

Neutral 

Not or not at all 
Satisfied 

Peer Consumers 

83,4% 

Peer providers 

77,2% 

12,3% 

17,8% 

4,3% 

5% 

Source: Task 2 survey, Base - All peer consumers (N=8705) and peer providers (N=8498) 

When comparing satisfaction between the (Re)Sale platforms and the collaborative 
platforms, consumer and provider satisfaction is, on average, the same. About 85% 
of  peer  consumers  are  satisfied  with  resale  platforms  and  75%  to  89%  of 
consumers are satisfied with collaborative platforms. Similarly, about 78% of peer 
providers are satisfied with resale platforms and 64% to 83% of the providers are 
satisfied  with  collaborative  platforms.  It  is  noticeable  that  peer  consumers  are 
slightly more satisfied than peer providers, especially for (Re)Sale goods platforms 
(85%  vs.  78%),  Sharing/Renting  Accommodations  platforms  (83%  vs.  73%)  and 
Odd Jobs platforms (74% vs. 64%). 

79  The  cities  where  the  fieldwork  took  place  are  London  (UK),  Milan  (Italy),  Paris  (France),  Nürnberg 
(Germany),  Madrid  (Spain),  Warsaw  (Poland),  Ljubljana  (Slovenia),  Sofia  (Bulgaria),  Hilversum  (The 
Netherlands) and Kopenhagen (Denmark).  

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Table  16:  Satisfaction  with  overall  experience  using  P2P  platforms  –  Peer 
Consumers 

Satisfaction with 
overall experience 
using P2P platforms 
– Peer Consumers 

(Very)  
Satisfied 

(Re)Sale of goods 

84,5% 

Sharing/Renting 
Goods 
Sharing/Renting 
Accommodation 
 Sharing/Hiring 
Rides 

Odd Jobs 

73,1% 

82,8% 

86,8% 

74,2% 

Neutral 

Not (at all) Satisfied 

11,4% 

22,3% 

11,7% 

9,7% 

21,1% 

4,2% 

4,6% 

5,5% 

3,5% 

4,7% 

Source: Task 2 survey, Base - All peer consumers (N=8705) 

Table  17:  Satisfaction  with  overall  experience  using  P2P  platforms  –  Peer 
providers 

Satisfaction with overall 
experience using P2P 
platforms – Peer Providers 

(Very)  
Satisfied 

Neutral 

Not (at all) 
Satisfied 

(Re)Sale of goods 

78,1% 

Sharing/Renting Goods 

72,6% 

Sharing/Renting 
Accommodation 

 Sharing/Hiring Ride 

Odd Jobs 

72,7% 

82,9% 

63,9% 

16,9% 

22,0% 

21,6% 

14,2% 

28,2% 

5,0% 

5,4% 

5,7% 

2,9% 

7,8% 

Source: Task 2 survey, Base - All peer providers (N=8498) 

Peer  consumers  who  were  active  on  P2P  platforms  were  also  asked  to  compare 
their  experiences  on  online  P2P  platforms  with  conventional  businesses.  Overall, 
they  are  more  satisfied  with  online  P2P  platforms  compared  to  conventional 
businesses.  About two thirds of peer consumers are more satisfied  with the prices 
on  P2P  platforms.  Around  60%  are  also  happier  with  the  price  quality  ratio,  the 
quality  of  services  provided  by  peers and  the  availability  of  offers  in  P2P  markets. 
Peer  consumers  rate  the  quality  of  goods  and  the  trustworthiness  of  their 
experiences  on  P2P  platforms  less  favourably  in  comparison  with  conventional 
business, but for almost half, there is no big  difference in product quality, and for 
40% there is no big difference in trustworthiness.  

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Table  18:  Satisfaction  with  experience  using  P2P  platforms  compared  to 
conventional business – Peer consumers 

Satisfaction with experience 
using P2P platforms compared 
to conventional business 

Price 

Availability of offers 

Quality of product sold by the 
peer 
Quality of service provided by 
the peer 

Price/quality ratio 

Trustworthiness 

(Slightly) more 
Satisfied 

Neutral 

(Slightly) less 
satisfied 

68,1% 

57,7% 

39,9% 

60,4% 

61,7% 

44,7% 

23,5% 

30,1% 

48,8% 

29,8% 

30,4% 

40,5% 

8,4% 

12,2% 

11,3% 

9,8% 

7,9% 

14,8% 

Source: Task 2 survey, Base - All peer consumers (N=8704) 

When  comparing  peer  consumer  satisfaction  with  P2P  platforms  and  conventional 
businesses  per  sector,  the  findings  show  that  for  most  factors,  both  consumers of 
(Re)Sale  platforms  and  consumers  of  collaborative  platforms  are  more  satisfied 
with these platforms  than they  are  with conventional  businesses.  Satisfaction with 
all these aspects is particularly high compared to conventional business services in 
the ride sharing (e.g. BlaBlaCar) and ride hiring (e.g. Uber) sector. Exceptions are 
satisfaction  with  products  and  trustworthiness,  where  especially  (Re)Sale  of  goods 
platform are evaluated as similar to conventional businesses.  

Table  19:  Satisfaction  with  experience  using  P2P  platforms  compared  to 
conventional business, sector breakdown 

(Re)Sale of goods 

Sharing/Renting 
Goods 

Sharing/Renting 
Accommodation 

Odd Jobs 

Sharing/Hiring Rides 

(Slightly
) more 
satisfied 

(Slightly
) less 
satisfied 

(Slightly
) more 
satisfied 

(Slightly
) less 
satisfied 

(Slightly
) more 
satisfied 

(Slightly
) less 
satisfied 

(Slightly
) more 
satisfied 

(Slightly
) less 
satisfied 

(Slightly
) more 
satisfied 

(Slightly
) less 
satisfied 

Price 

68,62% 

6,55% 

54,7% 

20,04% 

67,14% 

10,76% 

79,69% 

6,29% 

49,9% 

24,27% 

Availability of 
offers 

Quality of 
products 

Quality of 
service 

Price/quality 
ratio 

Trustworthines
s 

57,19% 

11,14% 

52,2% 

20,25% 

64,42% 

10,99% 

61,59% 

13,25% 

49,9% 

20,05% 

39,07% 

11,01% 

49,9% 

15,45% 

58,98% 

10,17% 

64,79% 

6,84% 

53,3% 

15,57% 

59,90% 

7,60% 

55,3% 

11,70% 

67,20% 

8,10% 

76,40% 

4,70% 

54,7% 

14,50% 

40,12% 

15,82% 

49,7% 

15,03% 

54,85% 

11,23% 

59,71% 

10,71% 

54,6% 

15,04% 

Source: Task 2 survey, Base- All peer consumers (N=8704) 

5.2  Peer consumer problems and personal detriment  

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The  survey  also  asked  peer  consumers  and  peer  providers  about  problems  they 
experienced  when  using  P2P  platforms,  and  peer  consumers  if  and  how  problems 
were solved and the level of personal detriment80 they suffered as a result. 

5.2.1  Problems experienced by peer consumers 

Over half of peer consumers (55%) reported that they had experienced at least one 
of  a  range  of  problems.  These  included  problems  with  the.  product/service  not 
being  as  described  or  of  poor  quality;  with  the  price  not  being  as  agreed  or 
additional costs, non-delivery of the product or cancellation, safety issues with the 
product  or  the  service;  personal  data  being  given,  resold  or  leaked  to  others,  or 
problems with  using  the  platform  during  the  last  12 months when using  an  online 
P2P platform.  

The  two  main  problems  are  that  the  product/service  was  either  of  poor  quality  or 
not as described.  

Table 20: Problems experienced – Frequency breakdown 

Problems experienced 

Never 

Once 

2 to 4 
times 

1.  Product/service was of poor quality 

71,3% 

20,2% 

6,7% 

5 or 
more 
times 
1,8% 

At least 
once 

28,7% 

2.  Product/service was not as described 

72,2% 

19,2% 

6,8% 

1,8% 

27,8% 

3.  Experienced problems with using the 

80,9% 

11,3% 

5,9% 

1,9% 

19,1% 

website/app/platform functions 

4.  Product was not delivered/Reservation was 

82,4% 

11,9% 

4,4% 

1,4% 

17,6% 

cancelled 

5.  Price was not as agreed or additional costs 

84,5% 

9,9% 

4,1% 

1,4% 

15,5% 

were not mentioned before 

6.  Experienced safety issues with the 

88,4% 

6,7% 

3,7% 

1,2% 

11,6% 

product/goods/accommodation/ride/job 

7.  My personal data were given, resold or 

90,1% 

5,1% 

3,4% 

1,5% 

9,9% 

leaked to others 

8.  Other  
Source: Task 2 survey, Base - peer consumers (N=8705) 

81% 

12,5% 

3,0% 

3,5% 

19% 

The  main  problems  (i.e.  goods  and  services  of  poor  quality  or  not  as  described) 
turn out to be the same in the (Re)Sale of goods sector and the collaborative sector 
(see  Table  21).  Across  the  collaborative  platforms,  however,  the  incidence  of 
problems  is  significantly  higher  in  the  renting/sharing  of  goods  and  odd  jobs 
sectors.  For  these  two  sectors,  problems  with  the  functioning  of  the  platform  or 
website and problems with the price were also reported relatively more often.  

80  Consumer  detriment  can  be  structural  or  personal.  While  structural  detriment  focuses  on  the  loss  of 
consumer  welfare  due  to  market  failure,  the  current  report  looks  at  personal  detriment,  which  is  the 
personal experience of those consumers for whom something goes wrong. 

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In addition, In the (Re)Sale of goods and Sharing/Renting Accommodations sector, 
there were significant differences between large and small platforms, but not for all 
types  of  problems.  In  the  (Re)Sale  of  goods  sector  problems  were  more  likely  to 
occur on larger platforms, with the exception of delivery or data security issues. For 
Sharing/Hiring  Accommodation,  there  were  no  significant  differences  between 
larger and smaller platforms regarding the frequency of the main problems (service 
not  as  described  and  quality  of  service)  but  other  problems  (issues  regarding  the 
price or cancellations) were more likely to occur on larger platforms. Finally, in the 
Odd  Jobs  and  Sharing/Renting  Goods  sector  there  were  few  significant  differences 
between  larger  or  smaller  platforms.  On  smaller  platforms  for  Sharing/Renting 
Goods  problems  of  non-delivery  (72.3%  vs  61.2%)  and  data  security  (80.5%  vs 
64.4%) were more frequent than on larger platforms.  

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Table 21: Problems experienced – Sector breakdown category 

Problems experienced – Sector breakdown 

(Re)Sale of goods 

Sharing/Renting 
Goods 

Sharing/Renting 
Accommodation 

Never 

84,1% 

88,6% 

Experienced problems with using the 
website/app/platform functions 
Price was not as agreed or additional costs were 
not mentioned before 
Product was not delivered/Reservation was 
cancelled 
Product/service was not as described 
Product/service was of poor quality 
Experienced safety issues with the 
product/goods/accommodation/ride/job 
My personal data were given, resold or leaked to 
others 
Other  
Source: Task 2 survey, Base - peer consumers (N = 8705) 

73,2% 
71,9% 
92,3% 

85,7% 

93,4% 

81,6% 

At least 
once 
15,9% 

Never 

58,9% 

At least 
once 
41,1% 

Never 

81,8% 

At least 
once 
18,2% 

Sharing/Hiring 
Ride 

Never 

79,6% 

At least 
once 
20,4% 

Odd Jobs 

Never 

57,4% 

At least 
once 
42,6% 

11,4% 

60,3% 

39,7% 

83,7% 

16,3% 

82,6% 

17,4% 

55,8% 

44,2% 

14,3% 

65,6% 

34,4% 

86,4% 

13,6% 

74,1% 

25,9% 

61,3% 

38,7% 

26,8% 
28,1% 
7,7% 

54,1% 
56,2% 
66,8% 

45,9% 
43,8% 
33,2% 

74,2% 
78,8% 
89,0% 

25,8% 
21,2% 
11,0% 

80,6% 
74,9% 
82,9% 

19,4% 
25,1% 
17,1% 

55,3% 
55,8% 
64,7% 

44,7% 
44,2% 
35,3% 

6,6% 

69,9% 

30,1% 

90,5% 

9,5% 

88,5% 

11,5% 

64,7% 

35,3% 

18,4% 

72,2% 

27,8% 

85,0% 

15,0% 

80,9% 

19,1% 

72,3% 

27,7% 

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5.2.2  Comparing  problems  experienced  using  P2P  platforms  versus  using  conventional 

businesses 

Overall,  when  comparing  P2P  platforms  with  conventional  businesses,  most  peer 
consumers  say  they  did  not  experience  similar  problems  when  using  conventional 
businesses;  only  26,4%  of  peer  consumers  say  they  had  the  same  problems  with 
conventional businesses.  

However,  the  survey  findings  suggest  that  this  percentage  is  somewhat  lower  for  the 
(Re)Sale of goods sector (where 23,8% experienced a similar problem). This proportion 
is  the  highest  for  the  sharing/renting  goods  platforms,  where  more  than  one  third  of 
respondents experienced similar problems. 

Table  22:  Experienced  similar  problems  when  using  conventional  business  – 
Sector breakdown 

(Re)Sale 
of goods 

Sharing/Renting 
Goods 

Sharing/Renting 
Accommodation 

Sharing/Hiring 
Ride 

Odd 
Jobs 

Yes 

No 

23,8% 

36,9% 

76,2% 

63,1% 

29,6% 

70,4% 

25,7% 

26,4% 

74,3% 

73,6% 

Source: Task 2 survey, Base - peer consumers who experienced at least one problem (N=4626) 

Comparing  these  results  with  the  findings  of  the  Digital  Single  Market  Study81,  about 
problems experienced in on-line shopping it can be observed that:  

  problems  with  quality  of  the  product  or  service  are  almost  twice  as  frequent  in 
P2P markets than in general online purchases - in the DSM survey 15% reported 
that  the  product/service  was  lower  quality  than  advertised,  whereas  28,7%  of 
users of P2P platforms in the current study report poor quality products/services 

  problems  with  non-delivery  and  cancellations  are  slightly  more  frequent  in  P2P 

markets - 13% in general online transactions and 17,6% in this P2P survey.  

Peer  consumers  were  asked  if  P2P  platforms  enable  them  to  save  money  compared  to 
conventional  businesses.  Overall,  68,8%  slightly  or  completely  agree  that  this  is  the 
case.  Nearly  a  third  do  not  believe  this  to  be  the  case,  indicating  there  is  a  significant 
minority of peer consumers on P2P platforms who value P2P platforms for reasons other 
than saving money. 

Table  23: Saving money  using a  P2P platform  in  comparison with conventional 
business (Peer consumers) 

To what extent do you agree that 
using the P2P platform enables 
you to save money, compared to 
conventional businesses 

Completel
y agree 

Slightly 
agree 

Neutral 

Slightly 
disagre
e 

Completel
y disagree 

Peer consumers 

27,2% 

41,6% 

19,1% 

7,4% 

4,7% 

81 
http://ec.europa.eu/consumers/consumer_evidence/market_studies/obstacles_dsm/docs/21.09_dsm_final_rep
ort.pdf  

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The  findings  of  the  focus  groups  further  clarify  that  P2P  platforms  are  associated  with 
good  price  deals  and  saving  money,  and  that  transactions  often  entail  small  sums.  In 
particular, (second hand) goods (notably clothes) and transportation are said to be up to 
70 or 80% less expensive on P2P platforms. With regard to accommodation and odd jobs 
some mention they are able to save, while others perceive the price level to be the same 
or even higher in comparison to the traditional economy. 

Saving  money  is  also  relative to  expectations:  savings  are  much  bigger if  imperfections 
of the product or the service are not given importance. And in the end respondents find it 
hard to estimate how much money they have really saved. While savings on BlaBlaCar or 
Uber  are  indisputable,  with  goods  one  would  not  necessarily  have  bought  it  for  the  full 
price.  

Although participants experience more problems and sometimes find it difficult to get to 
a  solution,  there  appears  to  be  a  higher  tolerance  towards  problems  on  P2P  platforms 
compared with conventional businesses. The risk of bad experiences is perceived as part 
of  the  deal  of  the  peer-to-peer  game.  Indeed,  current  P2P  platform  users  say  they  are 
aware  that  they  operate  in  a  relatively  unregulated  environment,  and  of  the  risks  this 
involves.  They  are  willing  to  take  the  risk  because  generally  only  small  amounts  of 
money  are  at  stake,  and  they  do not  use  P2P  platforms  to  make  a  living.  But  they  feel 
that  the  benefits,  in  particular  the  opportunity  of  savings  or  getting  a  better  deal, 
outweigh the risks. 

5.2.3  Consumer detriment 

Peer  consumers  were  also  asked  to  indicate  on  a  scale  of  0-10  to  what  extent  they 
suffered  personal  detriment  as  a  result  of  these  problems82.  Personal  detriment  in  this 
case is defined as financial loss or any other type of harm (e.g. loss of time, stress, etc.). 

On  average  the  level  of  personal  detriment  experienced  by  peer  consumers  was  low  to 
medium  in  all  sectors  (between  2,01 and  3,76).  It  is  notable  that  personal  detriment  is 
somewhat lower in the (Re)Sale of goods sector than in the collaborative sectors. Across 
the collaborative sectors, detriment is relatively higher in the sectors of Odd Jobs (3,76) 
and Sharing/Renting Goods (3,57). No data were gathered about the personal detriment 
experienced by peer providers.  

Table  24:  Average  level  of  personal  detriment  experienced  as  a  result  of 
problems experienced by peer consumers on P2P platforms 

(Re)Sale 
of goods 

Sharing/Renting 
Goods 

Sharing/Renting 
Accommodation 

Sharing/Hiring 
Ride 

Odd 
Jobs 

Detriment 

2,01 

3,57 

2,85 

2,48 

3,76 

Source: Task 2 survey, Base - Peer consumers who experienced at least one problem (N=4626, 10 MS) 

When  comparing  these  personal  detriment  levels  for  certain  categories  of  online  P2P 
platforms  with  markets  for  more  or  less  comparable  kinds  of  services  surveyed  in  the 
2015 Market Monitoring survey, the reported average personal detriment level on online 
P2P  platforms  is  lower  compared  to  the  detriment  level  in  corresponding  traditional 
consumer  markets.  The  comparison  may  be  biased  insofar  as  the  amounts  at  stake  on 
P2P  platforms  may  be  significantly  lower  compared  to  similar  products  and  services 
provided by conventional businesses, and they do not necessarily cover the same types 
of services.  

82 A level 0 means “No or negligible detriment” and 10 means “A very significant detriment 

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Table  25:  Average  personal  detriment  level  -  Comparison  between  online  P2P 
platforms and Market Monitoring 201583,84 

Average detriment level - comparison between online P2P platforms and Market 
Monitoring 2015 

Online P2P 
platforms 

Sharing/Hiring 
Rides Platforms 

Sharing/Renting 
Accommodation 
Platforms 

Odd Jobs 
Platforms 

Avg. detriment level 

Consumer Markets 

2,48 

2,85 

3,76 

5,3 

5,2 

5,8 

Vehicle Rental 
Services 

Holiday 
Accommodation 
Services 

House & Garden 
Maintenance 
Services 

Source: Task 2 survey, Base - Peer consumers who experienced at least one problem (N=4626) 

The  focus  groups  findings  confirm  that  people  experience  more  problems  with 
transactions  on  P2P  platforms  than  in  regular  transactions.  Problems  occur  more  often 
with  second-hand  items  or  services  and  in  cross border transactions.  Issues highlighted 
by  respondents  notably  included  products  or  services  not  corresponding  to  the 
descriptions, delayed or no delivery, last minute cancellations and no-shows of providers, 
fake accounts, and inappropriate behaviour.    

But  personal  detriment  is  often  not  considered  important  because  people  see  the  risk 
they take as "part of the game" and a lot of transactions are low cost or lower cost than 
in the traditional economy. 

5.3  Problems of peer providers 

Finally,  peer  providers  were  also  asked  about  any  problems  they  had  with  the  person 
they were providing the product/service to. 14% of providers experienced a problem with 
the other peer.  

The  occurrence  of  problems  ranges  from  11,3%  on  Sharing/Hiring  Ride  platforms  to 
16,4%  on  Sharing/Renting  Accommodation  and  21,9%  on  Odd  Jobs  platforms.  In 
comparison, providers experience in the (Re)Sale of goods sector are - with 13,4% - on 
the lower end of the range. 

Table 26: Incidence of problems experienced by providers with other peers 

Experienced 
problems with 
other peers 
Yes 

(Re)Sale of 
goods 

Sharing/Renting 
Goods 

Sharing/Renting 
Accommodation 

Sharing/Hiring 
Ride 

Odd 
Jobs 

13,4% 

16,1% 

16,4% 

11,3% 

21,9% 

No 

86,6% 

83,9% 

83,6% 

88,7% 

78,1% 

Source: Task 2 survey, Base -  peer providers (N=8498) 

83 Respondents in both the consumer survey  and Market Monitoring Survey 2015 were asked to indicate on a 
scale of 0-10 the what extent they suffered personal detriment as a result of problems experienced during the 
previous  year.  Based  on  the  answers,  an  average  detriment  level  is  calculated  for  a  selection  of  markets. 
Although  there  is  no  exact  concordance  between  the  markets  as  defined  in  the  Market  Monitoring  Survey,  a 
comparison can be still be made with the specific sectors as defined in the Sharing Economy survey due to the 
similarities between the nature of the services provided in these markets.  
84 A level 0 means “No or negligible detriment” and 10 means “A very significant detriment 

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The  most  frequent  problems  of  peer  providers  (47,5%)  were  related  to  payment, 
including  not  being  paid  by  the  other  peer,  having  to  wait  too  long  to  get  paid  or 
reimbursed or having to pay costs that were not mentioned before the transaction. Also, 
41% of peer providers who experienced a problem, indicated that the other peer did not 
show up or cancelled at the last moment. Finally, 27,5% had to deal with complaints and 
27% experienced damages. 

Table 27: Problem types experienced by providers  

Occurrence of problem 
25,8% 
6,1% 
8,1% 

Experienced problems with other peers 
I was not paid by the other peer 
My personal data were given, resold or leaked to others 
I experienced problems with using the website/app/platform functions 
The person I rented accommodation to caused damage to my 
property/The person I gave a ride to damaged my car/The person to 
whom I lent /rented a tool/device damaged it 
The person to whom I sold the product complained about it 
The person did not show up / cancelled at the latest moment 
The other peer did not follow the rules as mentioned on the platform 
I had to wait too long to get paid or reimbursed 
I had to pay costs that were not mentioned before during the 
transaction 
Other 
Source: Task 2 survey; Base: peer providers that have experienced a problem with the other peer (N=1188) 

27,5%86 
41%87 
20,8% 
24% 

27%85 

15,3% 

9,4% 

The findings above indicate that most problems  experienced by  providers are related to 
payment  issues  and  no  show/cancellation  issues.  On  the  collaborative  platforms,  both 
types  of  problems  are  experienced  almost  equally  often.  In  contrast,  of  all  problems 
reported  for  the  (Re)Sale  of  goods  sector,  cancellation  issues  were  never  mentioned, 
while half of the problems in this sector were payment-related. The findings for small and 
large  platforms are  also very  similar,  with  slightly  higher values  for both  problem types 
for large platforms. 

Table 28: Proportion indicating having experienced a payment issue or no show 
/ cancellation issue - Size & (Re)Sale vs collaborative breakdown 

Payment issues 

43,2% 

51,5% 

50,8% 

40,2% 

Small 

Large 

(Re)Sale 

Collaborative 

No show / cancellation 
issues 

40,2% 

50% 

0% 

41% 

Source: Task 2 survey, Base - Peer providers who experienced an issue with the other peer (N=1188) 

In  the  focus  groups,  bad  experiences  of  peer  providers  with  peer-consumers  related  to 
inappropriate  complaints  or  requests,  damage  of  property,  delays  in  payment  or  not 
paying  at  all,  no-shows  and  last  minute  cancellations,  fake  accounts  and  inappropriate 
behaviour or comments 

85  Includes  only  peer  providers  who  experienced  a  problem  using  Sharing/Renting  Accommodation, 
Sharing/Hiring Ride and Sharing/Renting Goods platforms (N=289). 
86 Includes only peer providers who experienced a problem using (Re)Sale Goods platforms (N=815). 
87  Includes  only  peer  providers  who  experienced  a  problem  using  Sharing/Renting  Accommodation  and 
Sharing/Hiring Ride platforms (N=200). 

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6  Clarity and transparency of information on P2P platforms  

This section draws on the in-depth analysis of 10 case study platforms in Task 4 as well 
as the consumer engagement in Tasks 2 and 3 to identify consumer issues with regard to 
clarity and transparency of information on P2P platforms.  

The main issues regarding clarity and transparency on P2P platforms concern: 

1.  Transparency and clarity about rights and responsibilities, notably with respect to 
the  role  of  the  platform  in  case  of  problems  with  the  transaction  –  in  terms  and 
conditions and other  

2.  Transparency  about  whether  the  peer  provider  is  a  business  or  a  professional  - 
and qualifies as a 'trader' under consumer law, or whether he is acting in a private 
capacity  

3.  Transparency about prices, in search results and about different price elements; 

4.  Transparency about how platforms protect the privacy and use the data of peers; 

6.1  Peer perceptions of clarity and transparency on P2P platforms 

The survey results clearly demonstrate that both peer consumers and peer provider have 
a low level of self-reported knowledge and a large amount of uncertainty regarding their 
rights  and  responsibilities  of  the  on  P2P  platforms.  Focus  group  results  further  indicate 
that  what  P2P  may  think  are  their  rights  on  P2P  platforms, is  not  necessarily  true.  This 
lack  of  knowledge  about  rights  and  responsibilities  for  peer  consumers  appears  to  be 
highest on Sharing/Hiring Rides and Sharing/Renting Accommodations platforms – while 
for  peer  providers  it  is  mostly  evident  for  (Re)Sale  goods  and  sharing/renting  ride 
platforms.  

At  the  same  time,  peers  attribute  major  importance  to  clarity  and  transparency  about 
rights and responsibilities. A large majority of peer consumers and peer providers across 
all P2P sectors (around 85% and 80% respectively) consider it (very) important that the 
online P2P platform is clear and transparent about their rights and responsibilities  

The consumer survey results show that about 85% of peer consumers think transparency 
about  rights  and  responsibilities  is  important  or  very  important.    More  than  85%  of  the 
peer  consumers  find  transparency  about  how  privacy  and  data  are  protected  by  the 
platform very important (52,4%) or important (33,7%); clarity about their rights in case 
there  is  a  problem  with  the  product  price  or  quality  is  very  important  (44,8%)  or 
important  (40,4%)  for  85,2%;  and  transparency  about  and  for  83.9%  transparency 
about  who  is  responsible  when  something  goes  wrong  is  very  important  (40%)  or 
important (43.9%).  

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Table 29: Importance of clarity and transparency about… - Peer consumers 

…who is responsible when something goes 
wrong 

13% 

44% 

40% 

…how privacy and data are protected 

12% 

34% 

52% 

…what my rights are if there is a problem with 
the price or quality of the product or the 
service 

13% 

40% 

45% 

0%

20%

40%

60%

80%

100%

Not important at all

Not important

Neutral

Important

Very important

Source: Task 2 survey, Base - peer consumers (N=8705) 

Similar  to  peer  consumers,  about  80%  of  peer  providers  are  concerned  about 
transparency  over  rights  and  obligations.  Almost  85%  of  them  find  transparency  about 
how privacy and data are protected by the platform very important (47.2%) or important 
(37,4%).  More  than  83%  consider  clarity  and  transparency  about  who  is  responsible 
when  something  goes  wrong  is  very  important  (37,2%)  or  important  (45,1%);and 
transparency about tax obligations is very important for 35,5%, and important for 41% 
of peer providers. The importance given to clarity and transparency about tax obligations 
was highest for peer providers on sharing/renting accommodation platforms. 

Table 30: Importance of clarity and transparency about… - Peer Providers 

…who is responsible when something goes 
wrong 

15% 

45% 

37% 

…how privacy and data are protected 

13% 

37% 

47% 

…tax obligations 

19% 

41% 

36% 

0%

20%

40%

60%

80%

100%

Not important at all

Not important

Neutral

Important

Very important

Source: Task 2 survey, Base - Peer providers (N=8498, 10MS) 

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The  survey  shows  that  a  majority  of  peer  consumers  and  peer  providers  either  don’t 
know  (between  15  and  19%  of  peer  consumers  and  peer  providers),  or  are  uncertain 
about  their  rights  (between  40%  and  45%  for  peer  consumers,  and  23%  and  24%  for 
peer  providers).  Only  around  one  third  of  peer  consumers  and  one  quarter  of  peer 
providers think they know their rights and responsibilities on P2P platforms. 

Table 31: Knowledge of rights for peer consumers and peer providers 

Knowledge of rights – Peer consumers 

Know exactly 

Not sure  
if I know 

Don’t know 

N/A 

Knowledge of rights when something goes 
wrong 
Knowledge of who is responsible when 
something goes wrong 
Knowledge of the responsibility of the 
platform in case of a problem with a provider 
of a service or a product 
Knowledge of the right to get compensation 
or be reimbursed if something goes wrong 
Knowledge of rights – Peer providers 

34,0% 

44,0% 

15,7% 

6,3% 

36,0% 

42,7% 

15,0% 

6,3% 

30,8% 

43,7% 

18,8% 

6,6% 

33,3% 

40,9% 

18,9% 

6,9% 

Know 
exactly 
25,5% 

More or 
less 
30,4% 

Not sure  
if I know 
23,4% 

Knowledge of rights when something goes 
wrong 
Knowledge of who is responsible when 
something goes wrong 
Knowledge of the responsibility of the 
platform in case of a problem with a provider 
of a service or a product 
Knowledge of the right to get compensation 
or be reimbursed if something goes wrong 
Source: Task 2 survey; Base: all peer consumers (N=8705) and peer providers (N=8498) 

28,6% 

27,4% 

29,5% 

24,0% 

23,2% 

23,0% 

26,3% 

24,8% 

27,5% 

Don’t know  N/A 

15,1% 

5,6% 

14,5% 

5,5% 

16,8% 

5,8% 

17,2% 

5,9% 

The focus groups results also indicate that most of the current users of P2P platforms are 
not  knowledgeable  about  the  applicable  rules.  Peer  consumers  may  incorrectly  assume 
that  basic  online  rights  apply  in  online  P2P  markets.  At  the  same  time,  peers  do  not 
actively  seek  to  know  more  about  their  rights  and  obligations  and  they  only  become 
interested  in  them  once  a  problem  occurs.    Many  focus  group  participants  expressed  a 
need  for  more  transparency  about  basic  rules  and  expected  a  role  for  the  platform  in 
this:  platforms  could  provide  users  with  a succinct  description  of  their basic  legal  rights 
and obligations.  

6.2  Platform  practices  and  approaches  to  clarity  and  transparency  of 

information 

To assess whether and how the above peer user concerns are related to actual platform 
practices, the case studies (Task 4 of this study) examined 10 platforms in greater detail.  

6.2.1   The contractual nature of the transaction 

The  contractual  nature  of  the  transaction  between  peers  can  be  difficult  for  peer 
consumers  to  determine  in  an  online  P2P  environment.  At  the  same  time,  whether  the 
peer  provider  is  an  individual  or  a  business  has  significant  implications  for  the 
applicability of consumer and marketing law. 

The findings from the case studies demonstrate that P2P online platforms have different 
practices  and  levels  of  transparency  regarding  the  legal  status  of  peer  providers  (Table 
32).  

Among the case studies, five platforms clearly make the distinction between private and 
commercial  (peer)  providers.  On  the  one hand,  some  platforms (BlaBlaCar  and easyCar 

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Club)  exclude  commercial  activity  by  peer  providers  and/or  businesses.  On  the  other 
hand,  several  platforms  (eBay,  Wimdu  and  Yoopies)  require  peer  providers  to  indicate 
their legal status; eBay and Yoopies also require peer providers to indicate on the listing 
or their profile whether they are a private individual or a business.  

The  remaining  five  platforms  (Airbnb,  Nimber,  Peerby,  Wallapop,  Uber)  do  not  make  a 
distinction  or  do  not  require  peer  providers  to  give  any  information  about  their  legal 
status.  

Furthermore, all platforms deny liability for false information provided by peers.  

Table  32:  Different  platform  approaches  regarding  transparency  about  private 
and commercial peer providers 

Approach 

Platform 

Tools 

Monitoring 

Only private peer 
providers can engage 
in P2P transactions on 
the platform 

BlaBlaCar 

easyCar Club 

Platform requires peer 
providers to indicate if 
they are private or 
commercial but does 
not prevent 
commercial providers 
from engaging on the 
platform 

eBay 

Wimdu 

Yoopies 

Airbnb 

Platform does not 
distinguish between 
private and commercial 
providers/does not 
require providers to 
indicate this   

Standardised T&Cs that 
define interaction 
between peers 
(Member’s agreement) 

Price caps and 
restrictions on the 
number of passengers 
reduce attractiveness 
for commercial 
providers 

Pre-screening before 
giving access to 
platform- 

Only allows private (and 
leased) cars   

Different profiles for 
commercial and private 
providers  

Shows peer provider 
status on the listing 
page 

Peer provider categories 
(private/commercial) 
based on 4 criteria  

Information and advice 
on the “auto-
entrepreneur status” in 
France 

Shows peer provider 
status on the listing 
page 

Professionally managed 
properties are expected 
to have 25 or fewer 
rooms and a full-time 
manager or owner 
available on site, as 
explained in special 
Hosting Standards 

May request and verify relevant 
documents  

Excludes liability for the validity of the 
information provided by peers 

Systematic case-by-case assessment  

Excludes liability for the validity of 
information 

Not mentioned,  

Excludes liability for the validity of 
information 

Not mentioned; occasional on-site visits  

Excludes liability for the validity of 
information 

Verifies official identity documents 

Excludes liability for the validity of 
information 

No information on monitoring or 
enforcement of guidance 

Excludes liability for validity of 
information  

Peerby 

Wallapop 

Yoopies 

Nimber 

Uber 
Pop/Pool88 

n/a 

n/a 

n/a 

n/a 

n/a 

Source: VVA analysis of case studies  

88 Uber peer providers can be either private individuals, or professional drivers with license, depending on countries. However, the platform’s T&Cs do not differentiate between the two 

statuses and designate peer providers indistinctly as "independent transportation providers”. 

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The distinction between private and commercial peer providers is most relevant for larger 
platforms,  which  are  much  more  likely  attract  professionals  and  (small)  businesses 
providing  commercial  services  because  it  gives  them  access  to  a  large  user  base.  But 
some of the largest case study platforms (e.g. Airbnb) still do not provide information on 
the peer provider’s legal status. The practice of larger platforms such as Airbnb enabling 
peer  providers  to  conclude  transactions  without  distinction  of  their  legal  status  is 
therefore  a  major  obstacle  to  transparency  about  rights  and  responsibilities  for 
consumers. 

6.2.2  Pricing 

The  case  study  platforms  have  different  practices  and  approaches  to  transparency  in 
pricing.  Most  platforms  (six  out  of  10)  at  the  point  of  purchase  give  the  total  price  and 
separate the different elements included in the price, but there are important variations 
in the detail of the breakdown. None of the platforms that charge fees to peer providers 
indicate this information in the total price shown to consumers.   

Table 33: Information about pricing  

Platform 

Notes 

Details of 
what is 
included in 
the price  

Add-on 
services 

Breakdown 
of the price 
paid to 
platform and 
to the peer 
provider  

Airbnb 

X 

NA 

X 

  Price shown to peer consumer separates price of the 

accommodation, transaction fee charged to peer consumers, add-
on services (e.g. cleaning fees); 

  Price shown to peer consumer does not indicate the transaction 

fee charged to the peer provider  

BlaBlaCar 
(transaction fee 
model)  
easyCar Club 

EBay 

X 

X 

NA 

NA 

  Price shown to peer consumer separates price of the ride, and 

transaction fee charged to peer consumers.  

NA 

  Peer consumers can only see the total price amount.  

NA 

  Price shown to peer consumer separates the price of the item and 

shipping fees; 

  Price shown to peer consumer but does not indicate the 

transaction fees charged to the peer provider (when applicable). 

Nimber 

X 

NA 

NA 

  Price shown to the peer consumer separates the price of the 

Peerby Go 

UberPool 

UberPop 

X 

Wallapop 

Wimdu 

NA 

X 

NA 

NA 

NA 

NA 

NA 

NA 

NA 

X 

NA 

Yoopies 
(transaction fee 
model, in France 
only) 
Source: VVA analysis of case studies  

parcel and transaction fees, but does not separate service fee and 
insurance. 

  Peer consumers can only see the total price amount.   

  Price shown to the peer consumer does not separate the 

transaction fee charged to peer consumer.  

  Price shown to the peer consumer does not separate the 

transaction fee charged to peer consumer.  

  Price shown to the peer consumer after the ride separates base 

fare, time and distance.  

  Does not charge fees to peer users. 

  Price shown to peer consumer separates price of the 

accommodation, transaction fee charged to peer consumers, add-
on services (e.g. translation fees); 

  Price shown to peer consumer does not indicate the transaction 

fee charged to the peer provider. 

  Peer consumer can only see the total price amount.   

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Most platforms separate the total cost shown to peer consumers between different price 
components, including: 

  The price of the product or service charged by the peer provider; 
  The transaction fee charged by the platform to peer consumers (if any);  
  Other fees included in the price (e.g. for delivery, insurance); 
  Fees for add-on services (insurance) 
  Other costs (e.g. cleaning costs) or security deposits; 

Generally,  on  most  case  study  platforms,  the  prices  displayed  in  search  results  do  not 
include  platform  transaction  fees.    This  means  the  total  price  is  not  shown  to  peer 
consumers  when  selecting  a  listing,  and  the  total  price  of  the  transaction  may  not  be 
clear until the booking is made 

The only exception  among the case studies is the French language version of BlaBlaCar 
where the price displayed in search results does include the transaction fee.89  UberPop 
and  Yoopies  offer  an  estimate  of  the  total  price  to  be  paid  before  the  transaction  is 
undertaken.  Uber  gives  fare  estimates  in  each  city.  On  Yoopies  peer  consumers  can 
simulate their budget on the basis of average hourly rates. 

None of the platforms charging transaction fees to peer providers (Airbnb, eBay, Wimdu) 
show this amount separately in the total price paid by peer consumers.  

Information about cancellation fees in case peer consumers decide to cancel a booking is 
accessible  on  most  platforms  (Airbnb,  BlaBlaCar,  eBay,  easyCar  Club,  Nimber,  Peerby 
Go,  Wimdu,  Yoopies),  either  in  the  Help  section  or  in  T&Cs.  Cancellation  policies  are 
explained  by  Airbnb,  BlaBlaCar,  easyCar  Club,  eBay,  Peerby  Go,  Uber,  Wimdu  but  the 
exact amount of the cancellation fee is not displayed by Airbnb, Wimdu or BlaBlaCar.  

Platforms  that  recommend  prices  (e.g.  Airbnb,  Wimdu,  Yoopies,  Nimber),  set  maximum 
prices  (Uber,  BlaBlaCar)  or  set  'dynamic'  prices  (e.g.  easyCar  Club  “market  pricing” 
option  or  Airbnb  “smart  pricing”  option)  do  not  make  their  algorithms  for  calculating 
prices  public,  but  all  of  these  platforms  clearly  state  which  type  of  data  are  taken  into 
consideration. The fact that information is not available is more problematic for platforms 
that set prices, because peers have no or little leeway to change these (e.g. Uber sets a 
maximum price per ride, whereas BlaBlaCar sets a range of +/- 50%). On platforms with 
"dynamic" pricing mechanisms that set prices in function of daily or hourly fluctuations in 
supply  and  demand  and/or  other  factors  (e.g.  Airbnb,  Peerby  Go,  Nimber,  Uber)  prices 
may change considerably over time, both for peer providers and peer consumers. 

To  conclude,  the  level  of  transparency  about  pricing  is  insufficient  on  the  case  study 
platforms  examined  for  this  study,  in  particular,  in  the  search  results.  Most  platforms 
separate  different  elements  of  the  price,  but  this  is  not  done  in  a  systematic  way 
between the transaction fees charged by the platform to peer consumers and providers, 
and  potential  add-on  services.  None  of  the  platforms  using  algorithms  to  set  or 
recommend prices publish precise information on how this is done.  

The  results  are  consistent  with  the  survey  which  found  that  between  11.4%  (resale  of 
goods) and 44.2% (odd jobs) of peer consumers had experienced at least once that the 
price  was  not  as  agreed  or  additional  costs  had  not  been  mentioned  before  the 
transaction (see also Section 5.3.1).  

6.2.3  Terms and conditions 

The  screening  of  485  platforms  found  that  86%  of  P2P  platforms  set  terms  and 
conditions  for  platform  use  and  35%  also  set  terms  or  conditions  for  the  interaction  or 
transactions  between  the  peers  (see  Section  3.1).  The  10  case  study  platforms  all  set 
standardised  terms  and  conditions  for  using  the  platform  and  some  of  these  (Airbnb, 

89 BlaBlaCar case study report, section 2.4.1. 

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BlaBlaCar,  eBay,  Peerby  and  UberPool/UberPop)  also  set  terms  or  conditions  for  the 
interactions or transactions between peers.  

All  platforms structure their T&Cs  into  different  paragraphs  and  headings.  However,  the 
length  of  the  document  and  technical  nature  of  the  vocabulary  employed  impair 
transparency  about  key  responsibilities,  rights  and  obligations.  With  the  exception  of 
Peerby Classic, T&C's are at least 10 pages long, and add up to 30 pages on Airbnb and 
Wimdu. Airbnb’s T&Cs are spread between 10 different documents, which is an additional 
obstacle to transparency.  

Unlike the nine other platforms, Peerby T&Cs are brief (approximately one page). Peerby 
Classic’s  T&Cs  are  fairly  complete,  containing  provisions  about  platform  use  and  peer 
interactions.  Peerby  Go’s  T&Cs,  on  the  other  hand,  lack  important  elements  about 
liability, complaints handling mechanism, price setting, or insurance.  

Among the platforms selected for an in-depth case study analysis, insofar as the role and 
responsibility  of  the  platform  is  explained,  this  is  mainly  to  exclude  responsibility  or 
liability. There is no clear information about applicable consumer or contractual rights, or 
who  is  responsible  if  something  goes  wrong.  However,  on  most  platforms  there  are 
extensive FAQ sections explaining to peers what to do in case of problems, which creates 
the  impression  the  platform  does  assume  responsibility  and  will  provide  assistance  in 
case of problems. 

All  T&Cs,  except  Peerby  Go  which  does  not  specify  any  information  about  liability, 
exclude  the  platforms’  liability  or  responsibility  for  the  interactions  and  transactions 
between  the  peers,  irrespective  of  how  much  control  the  different  platforms  have  over 
the  P2P  transaction.  None  of  the  case  study  platforms  assume  responsibility  for  the 
accuracy of information provided by peers, including information on their identity or legal 
status. 

At  the  same  time,  and  despite  this  exclusion  of  liability,  the  T&Cs  of  several  platforms 
contain  provisions  that  directly  govern  the  transaction  and  /or  interactions  between  the 
peers, and they indicate that platforms can sanction peers in case of non-respect of those 
provisions.  

  Airbnb’s  T&Cs  state  that  users  must  comply  with  the  Community  Standards,  the 
set of policies regulating interactions between peers. “Airbnb reserves the right, at 
any time and without prior notice, to remove or disable access to any Listing for 
any  reason,  including  Listings  that  Airbnb,  in  its  sole  discretion,  considers  to  be 
objectionable for any reason, in violation of these Terms or Airbnb’s then-current 
Policies and Community Guidelines or Standards.” 

  BlaBlaCar’s T&Cs contain provisions of the Member’s Agreement, also available in 
a separate document. They can be found in a section about “Behaviour of users of 
the  Platform  and  Members”  that  define  the  undertakings  of  the  drivers  and 
passengers.  It  is  specified  that,  in  case  of  breach  of  the  T&Cs,  the  platform  can 
“(i)  terminate  the  T&Cs  immediately  and  without  notice,  and/or  (ii)  prevent  the 
posting of or remove reviews or content posted on the platform, and/or (iii) limit 
the access and use of the platform, and/or suspend your account.”   

  Similarly, Uber’s Community Guidelines set rules about respect, safety, feedbacks 
for both drivers are riders. They state that, in case of problematic behaviour, the 
user  “may  lose  access  to  Uber”  through  “immediate  loss  of  access  to  your 
account”. 

  eBay  has  a  Member  to  member  contact  policy  and  a  Discussion  board’s  usage 
policy  setting  guidelines  for  communication  between  the  peers.  They  specify  to 
the user: “Make sure you follow these guidelines. If you don't, you may be subject 
to  a  range  of  actions,  including  your  messages  being  blocked,  limits  of  your 
buying and selling privileges and suspension of your account.” 

  eBay’s  T&Cs  deny  liability  for  issues  resulting  from  platform  use  and  P2P 
interactions, but has provisions in case the platform would be “found to be liable”, 
although  the  platform  does  not  specify  the  circumstances  in  which  this  may 
happen.  

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  Peerby’s Classic T&Cs contain provisions about P2P interactions. They specify the 
purpose of the platform, and prohibit inappropriate requests. They state that the 
platform  reserves  the  right  “to  refuse  use  of  Peerby  or  any  other  service  to 
anyone, for any reason.” 

Moreover,  platforms  which  in  practice  set  the  key  terms  of  the  P2P  transaction,  i.e. 
control  payments,  monitor  performance  and  sanction  non-performance,  and  handle 
complaints  and  refunds  nonetheless  exclude  all  liability  for  the  P2P  transaction  –  as 
described  in  section  4.6,  these  are  Airbnb,  BlaBlaCar,  eBay  (in  part),  easyCar  Club, 
Nimber, Peerby Go, Uber, and Wimdu.  

In  particular,  these  case  study  platforms  in  practice  set  at  least  part  of  the  contractual 
terms  of  the  P2P  transaction.  This  may  create  the  impression  among  users  that  the 
platform  shares  a  certain  degree  of  responsibility  in  case  of  non-performance  or  non-
compliance of the performance. For instance, such impressions can be created by:  

  holding  payments  until  performance/compliance  of  the  service  is  confirmed  or 
withholding payment in case of non-performance or non-compliance by peers. 

 

 

 

 

imposing rules and fees for cancelations by peer consumers or peer provider.  

intervening to solve problems between peers through management of complaints, 
mediation of disputes and award of refunds. 

intervening  to  enhance  safety  and  security  by  verification  of  peer  identities,  or 
creating the impression that identities are verified. 

(optional)  automatic  price-setting  based  on  algorithms  using  internal/external 
demand/supply data. 

At the same time, the terms and conditions of these platforms systematically exclude any 
liability  of  the  platform  in  relation  to  the  contracts  concluded  between  the  peers,  and 
explicitly  state  that  the  platform  is  not  a  party  to  such  contracts.  For  instance,  all  case 
study platforms exclude liability for: 

 

the accuracy of information provided by the peer to establish whether they are a 
commercial or a private provider; 

  non-performance, non-compliance of the performance by the peer providers; 

 

the accuracy of information provided in peer-to-peer reviews. 

The discrepancy between the platforms' level  of intervention in setting the terms of the 
P2P transaction and the liability clauses in its T&Cs risks to confuse or mislead users with 
regard to the responsibility of the platform in case of problems with the P2P transaction. 

6.2.4  Data and data protection 

There are a number of potential data protection concerns regarding the process by which 
information  on  people’s  personal  habits,  behaviours,  plans,  services  or  products  they 
purchase, as well as contacts/friends is used currently by platforms or might be used in 
the future. As pointed out by the OECD Paper on Protecting consumers in peer platform 
markets,90  a  lack  of  data  sharing  policy  information  is  combined  with  the  risk  of  data 
breaches that can affect peers’ personal information. Platforms that hold extensive data 
on providers and consumers may have the technical capacity not only for dynamic pricing 
in function of both supply and demand but also for selective matching of peer consumers 
and providers, in terms of the type of product service and/or prices. Such practices could 

90 OECD (2016). Protecting Consumers in Peer Platform Markets: Exploring the issues. OECD Digital Economy Papers 
(253). 

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also lead to consumer discrimination, as underlined by a European Parliament study91, as 
well as other studies, especially for (re)sale platforms.,92,93 

P2P  platforms  collect  different  types  of  data  at  various  stages  of  platform  use.  For 
example,  Uber  collects  location  information;  contact  information  stored  on  the  peer 
consumer’s  device  (if  access  is  given);  transaction  details;  usage  and  preference 
information, e.g. through cookies and pixel tags; call and SMS data of contacts between 
the  customer  and  the  driver;  and  log  information.94  Airbnb  indicates  that  the  platform 
collects data given by peers when they set or update their account, or when they search 
for or post properties, as well as data not directly given by peers but produced when they 
use  the  platform  such  as  their  mobile  data,  contact  information,  log  data,  cookies 
recording the date, time and length of the visit.  

 Transparency  about  the  data  that  platforms  collect,  who  they  share  data  with  or  sell 
them  to,  as  well  as  information  about  data  protection  rules  that  apply  is  important  for 
both  peer  providers  and  peer  consumers  since  these  platforms  hold  a  lot  of  both 
behavioural  and  personal  data  about  them.  For  example,  Airbnb  can  hold  important 
personal  and  behavioural  data  such  as  the  peer’s  ID  card,  driver's  licence  or  passport; 
email  address,  first  name,  surname,  payment  details,  picture;  data  on  dates,  time  and 
length  of  visits,  and  how  the  platform  is  used  (search  and  purchasing  data);  data 
retrieved from mobile devices; data stored on Facebook, Google, or LinkedIn accounts.95  

Almost  half  (46%)  of  the  485  platforms  screened  use  or  do  not  exclude  using  data  to 
earn  revenue  as  part  of  their  monetisation  strategy.  They  do  so  either  by  sharing  or 
selling data to third parties for marketing purposes, or by not excluding that they may do 
this. Across sectors, Re(Sale) of Goods platforms are the principal data (re)users (59%), 
after  Sharing/Renting  Accommodation  (49%),  Odd  jobs  (39%),  Sharing/Hiring  Ride 
(36%) and Renting/Sharing Goods platforms (30%).96   

The  level  of  transparency  regarding  data  (re)use  and  data  protection  was  found  to  be 
uneven among the case study platforms.  

Table 34 : Platform data protection and data sharing policies 

Platform 

Platform shares data with third 
parties 

Platform provides data sharing 
policy 

Airbnb 
BlaBlaCar 
easyCar Club 
eBay 
Nimber 
Peerby Classic 
Peerby Go 
Uber Pop/Pool 
Wallapop 
Wimdu 
Yoopies 
Source: VVA analysis of case studies  

X 
X 
X 
X 
X 
X 

X 
X 
X 
X 

X 

X 

X 

X 

choice. 

91 European Parliament (2013). Discrimination of Consumers in the Digital Single Market. Internal Market and 
Consumer Protection Committee, p. 15. 
92  Ursu,  R.  M.  (2015).  The  power  of  rankings:  Quantifying  the  effects  of  rankings  on  online  consumer  search 
http://www.law.northwestern.edu/research-
at: 
and 
faculty/searlecenter/events/internet/documents/Ursu-Ranking_v2.pdf 
93  Ghose,  A.,  Ipeirotis,  P.,  Beibei,  L.  (2012).  Examining  the  Impact  of  Search  Engine  Ranking  and 
Personalization  on  Consumer  Behavior:  Combining  Bayesian  Modeling  with  Randomized  Field  Experiments. 
Available at: http://www.ipeirotis.com/wp-content/uploads/2012/01/wise2011_SearchDesign.pdf  
94 Uber case study report, section 2.3.3. 
95 Airbnb case study report, section 2.3.3. 
96 Ibid.  

Available 

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All platforms have policies dedicated to data protection (referred to as “privacy policy”), 
except  Peerby  Go.  These  privacy  policies  contain  elements  on  data  collection,  use  and 
sharing by the platform.  

Most platforms do not have a clear data use policy regarding transfers to third parties. All 
of them indicate they share data with third parties. However, only BlaBlaCar, eBay, Uber 
and  Yoopies  mention  that  they  only  do  so  with  user  consent.  BlaBlaCar  is  the  only 
platform  to  mention  that  data  is  not  shared  with  third  parties  against  payment.  For 
example: 

  BlaBlaCar  gives  a  limited  list  of  third  parties  to  which  information  is  disclosed, 
which includes other peers at the time of booking, payment processors at the time 
of  payment,  service  providers 
law  enforcement 
authorities, etc. The platform indicates that it does not disclose any information to 
third parties besides those in the list97 and it underlines that the platform “will not 
resell  your  information  to  any  third  party  nor  use  it  for  any  third-party 
marketing.” 

identity  verification, 

for 

  eBay  mentions  service  providers  and  financial  institutions,  law  enforcement 
authorities,  other  companies  that  are  part  of  the  eBay  group,  and  other  peer 
users, with details on what the data is used for.98 eBay explicitly states it will not  
"sell  or  rent  personal  information  to  third  parties  for  their  marketing  purposes 
without your explicit consent.” 

While  platform  privacy  policies  give  information  on  data  held  and  what  is  used  for,  the 
level  of  detail  provided  in  the  policies  analysed  in  the  case  studies  varies  significantly. 
Airbnb, easyCar Club, Nimber, Wallapop, Wimdu do not exclude sharing or selling profile 
or behaviour data to third parties without user consent.  

To conclude, P2P platforms rely extensively on the collection, use and sharing of data to 
provide  their  services.  Gaps  in  transparency  about  these  practices,  especially  data 
transfers  to  third  parties,  could  raise  major  issues  for  consumers.  The  survey  results 
have  shown  that  problems  with  personal  data  being  sold,  leaked  or  shared  with  others 
affect  between  6.6%  (resale  of  goods)  and  35.3%  (odd  jobs)  of  peer  consumers  and 
clarity  and  transparency  about  how  data  and  privacy  are  protected  is  one  of  the  most 
important issue for both types of peers with 84-86% of users considering this important 
or very important (see also Section 6.1). 

97 BlaBlaCar case study report, section 2.3.3. 
98 eBay case study report, section 2.3.3. 

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7  Trust building & verification of information on P2P platforms 

While  conventional  businesses  generate  consumer  trust  through  compliance  with 
governmental  regulations,  platforms  seek  to  generate  trust  through  a  variety  of  trust-
building  tools.  Peer  reviews/ratings  and  reputation  systems  are  the  most  prominent 
“trust  building  tools”  across  all  platforms  and  they  are  often  presented  by  platforms  as 
their  main  instrument  for  protecting  peer  consumers  and  peer  providers  against  fraud 
and  other  risks  and  for  ensuring  the  quality  of  goods  and  services  and  reliability  of 
providers. 

The  OECD  Digital  Economy  Paper  on  “Protecting  consumers  in  peer  platform  markets” 
points out that "trust is the key issue for consumers in peer platform marketplaces". Peer 
consumers can lack trust in the reliability and qualifications of peer providers, the quality 
of  the  product  or  service,  or  the  safeguards  offered  by  the  platforms.99  In  response  to 
negative consumer experiences such as identity theft, fraud, or safety issues, platforms 
have introduced the  possibility  to  complain,  to  access  redress  options,  or to  be  covered 
by an insurance. 

To help ensure reliability and quality, and to address risks such as fraud, identity theft or 
safety issues, P2P online platforms have developed a number of mechanisms. The OECD 
paper  identifies  the  following  main  categories  of  trust-building  tools  or  trust-building 
mechanisms:100  

  Review  and  reputation  systems.  Peer  review  systems  help  consumers  to  make 
informed  choices  by  giving  them  access  to  other  peers’  feedback  on  the  peer 
provider  and/or  the  product/service.  Reputation  systems,  on  the  other  hand, 
inform about  the  peer provider’s  reliability.  In  addition  to  having  a trust-building 
function,  review  and  reputation  systems  can  also  help  regulate  peer  behaviour 
through  peer-pressure,  or  help  the  platform  monitor  and  enforce  rules  and 
minimum requirements. Their effectiveness depends on a number of factors, such 
as the involvement of both platforms and peers, and the size of the platform.  

  Guarantees  or  insurance  schemes.  These  mostly  aim  to  provide  additional  cover 
for peer providers assets; they can be free of charge or included by default in the 
transaction fee, or available as add-on services. These are addressed in Section 8.  

  Verified  identities.  Face-to-face  interaction  between  peers  occurs  late  (or  never) 
on  online  P2P  platforms,  which  increases  risks  of  identity  theft,  fraud  or  safety 
issues.  Some  platforms  verify  peer  user  data,  but  most  do  not  verify  identity  on 
the  basis  of  official  documents.,  User  data  are  usually  checked  by  confirming  an 
email address, or by linking to the peer’s social media account. Pre-screening (by 
the peer platform). As an additional mean to verify identity, some platforms offer 
pre-screening of peer providers through verification of external data bases such as 
motor vehicle records or criminal background checks.  

  Secure  payment  systems.  Many  peer  platforms  offer  payment  services,  often  in 
co-operation  with  established  external  payment  system  providers.  The  safety  of 
payment systems is outside of the scope of this report. 

  Guidance  and  information  (or  "education")  for  users.  Platforms  may  offer 
information about rights and obligations, or give advice to peers to increase safety 
and  quality.  The  value  of  this  information  varies  depending  on  its  accuracy,  the 
level of detail and clarity. 

As  the  OECD  Digital  Economy  Paper  highlights,  the  effectiveness  of  these  trust-building 
mechanisms in achieving consumer protection outcomes is still to be determined.101  

99 OECD Paper, op. cit., p.17. 
100 OECD Paper, op. cit., p. 18. 
101 OCDE Paper, op. cit., p. 18. 

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7.1  Peer perceptions of peer reviews, ratings and reputation systems 

As highlighted by the OECD, the effectiveness of peer review and rating systems as trust-
building  tools  depends  on  the  active  involvement  of  both  peer  platforms  and  peers.  In 
particular,  these  tools  are  “clearly  less  effective  without  a  critical  mass  of  participating 
peers”.102  

The survey data show that a majority of peer consumers and peer providers do not use 
peer  reviews  or  ratings  systematically.  Only  about  40%  of  peer  consumers  and  peer 
providers use reviews regularly.  

A  small  majority  of  peer  consumers  conclude  transactions  without  verifying  reviews  of 
the  peer  providers,  and  a  definite  majority  do  not  contribute  reviews  after  the 
transaction.  

This indicates that reviews are unlikely to reflect the experience of all platform users, but 
rather to represent those of a smaller number of more involved peers.  

Even those peer consumers who experienced a problem, most did not take any action at 
all, and only about a fifth of those who did take action, gave a low ranking or bad review 
in response to the problem.  

It is therefore likely that the reviews and ratings posted by peer consumers do not reflect 
the experience of all platform users but rather those of a more active minority and may 
be biased as negative experiences appear in a majority of cases not to result in review or 
rating activity.  

Table  35 :  Use  of  review/rating  systems  by  peer  consumers  and  providers 
before and after a transaction (consumers and providers) 

Use review/rating systems 
before a transaction 

Never 

Rarely 

Sometimes  Frequently 

Always 

Peer consumers 

14,7% 

10,9% 

25,7% 

26,7% 

22% 

Peer providers 

21,2% 

13,5% 

25,4% 

22,2% 

17,7% 

Use review/rating systems 
after a transaction 

Never 

Rarely 

Sometimes  Frequently 

Always 

Peer consumers 

17,6% 

13,8% 

26,4% 

21,7% 

20,5% 

Peer providers 

23% 

14,3% 

24,1% 

20% 

18,6% 

Base: All peer consumers (N=8705) and peer providers (N=8498) 

The general pattern of irregular usage of rating and review systems prevails in all sectors 
examined.  Only  on  accommodation  platforms  59%  of  peer  consumers  use  reviews  or 
ratings  always  or  frequently  before  a  transaction,  but  after  their  transaction  only  46% 
give a rating or review. 

The survey indicates that is limited use of peer review and rating systems may be partly 
explained by a lack of confidence of P2P users have in such systems:  

  While most peer consumers generally evaluate user review systems as a positive 
contribution to safety and protection and adequate information (those who agree 
completely and those who slightly agree), three quarters of peer consumers have 

102 OECD Paper, op. cit., p. 18. 

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at least some reservations about the reliability of user review systems and do not 
think they necessarily provide complete safety and protection (those who slightly 
agree, neutral, and disagree slightly or completely).   

  Use of a review system clearly increases trust in the platform for almost 20% of 
peer consumers. But almost 40% only slightly agree with this statement, a sizable 
minority of 34% are neutral and almost 10% disagree. 

Table 36: Peer consumer views regarding the user review/rating systems 

I feel safer and more protected buying, renting, hiring
through conventional businesses

9% 

38% 

33% 

16% 

I feel safer and more protected using the user
review/rating system

6% 

22% 

44% 

25% 

The user review/rating system gives me adequate
information about the quality and trustworthiness of the
product/seller

6% 

24% 

45% 

22% 

My trust in the platform increased after using the review
system

6% 

34% 

38% 

19% 

Completely disagree

Slightly disagree

0%

20%
Neutral

40%

60%

80%

100%

Slightly agree

Completely agree

Source: Task 2 Survey; Base: all peer consumers (N=8705) 

Focus  group  findings  also  provide  clear  indications  about  awareness  about  the 
subjectivity  of 
their 
representativeness, as it is not clear whether people tend to write reviews more often or 
not after they have experienced a problem.  

respondents  underlined  uncertainty  about 

reviews,  and 

This  is  consistent  with  other  studies  which  have  found  that  reviews  are  perceived  as 
more  or  less  useful depending  on  the  identity  of  the  reviewer and the  characteristics  of 
the  review103,  and  that  the  lack  of  information  about  how  platforms  select  and  present 
peer  reviews  can  raise  questions  about  their  accuracy  and  objectivity.104  Others  have 
pointed to the fear of retaliation (i.e. the peer consumer is concerned about having a bad 
rating  in  return)  or  collusion  (i.e.  both  peers  implicitly  agree  to  give  each  other  good 
ratings),105  including  in  cases  of  feedback  reciprocity  where  the  peer  provider  has  the 
possibility to reply to feedback received.106  The problem of fake reviews was also raised 
in  the  public  consultation  on  the  regulatory  environment  for  platforms,  online 
intermediaries, data and cloud computing and the collaborative economy107.  

The focus group findings give some indications that for some types of users trust may be 
linked  to  the  size  of  the  platform,  though  this  was  not  investigated  in  the  survey.  For 
others,  the  local  nature  of  small  platforms  is  seen  as  a  great  advantage  as  proximity 
creates  a  basis  for  trust.  Furthermore,  a  strict  registration  system  also  appears  to  help 
inspire towards the platform.  

103 Pradeep R., Wesley F., “Perceived ‘usefulness’ of online consumer reviews: An exploratory investigation across 
three services categories”, Electronic Commerce Research and Applications, Vol. 11, no. 6, p.  
104 OECD Paper, op. cit., p. 18. 
105 Slee T., 2013, “Some obvious things about Internet reputation systems”, p. 7. Retrieved on: 
http://tomslee.net/wordpress/wp-content/uploads/2013/09/2013-09-23_reputation_systems.pdf 
106 Bolton et. al, 2012, “Engineering trust. Reciprocity in the production of reputation information”, p. 26. 
107 European Commission, 2016, Synopsis report on the public consultation on the regulatory environment for 
platforms, online intermediaries, data and cloud computing and the collaborative economy. Retrieved on: 
https://ec.europa.eu/digital-single-market/en/news/public-consultation-regulatory-environment-platforms-online-
intermediaries-data-and-cloud. 

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The  survey  and  focus  group  results  show  that  peers  engaged  in  P2P  markets  do  not 
systematically  use  and  do  not  always  trust  peer  reviews  and  ratings.  Instead  of  relying 
only  on  peer  reviews  and  ratings,  peers  seem  to  evaluate  the  overall  reliability  of  a 
platform and of its peer providers based on a combination of elements.Comparisons with 
conventional  businesses,  show  that  about  50%  of  peer  consumers  feel  more  protected 
when  interacting  with  conventional  businesses  than  when  interacting  with  the  P2P 
platforms  and  almost  40%  do  not  see  much  difference,  and  12%  disagree  that 
conventional business transactions are safer or offer more protection. 

7.2  Platform practices regarding peer review, ratings and reputation systems  

Over  time,  ratings  and  reviews  received  by  peers  can  be  aggregated  into  an  overall 
assessment  of  the  peer  (i.e.  the  peer’s  “reputation”)  which  can  be  endorsed  by  the 
platform. According to Slee (2013), reputation is a “sign of trustworthiness manifested as 
testimony by other people”.108 Applied to the context of P2P platform economy, it can be 
defined as the social capital built by peers with the trust they accumulated as a result of 
their online activities. This trust is captured with the data available on P2P platforms, for 
instance reviews and ratings.109 Botsman (2012) coined the term “reputation capital” to 
define trust stemming from the peer activity on a particular online P2P platform.110  

Peer review, rating and reputation systems are a key feature of P2P platforms across all 
sectors  and  countries.  Over  half  (52%)  of  the  485  platforms  screened  feature  a  peer 
review or reputation system. Peer review, rating and reputation systems are a common 
feature on the case study platforms: All case study platforms except Peerby provide such 
a system.  

The  Table  below  provides  an  overview  of  the  peer  reviews  and  reputation  systems 
available on the case study platforms which were analysed in greater depth in Task 4 of 
the study. 

108 Slee T., op. cit., p. 3. 
109 Balaram B., 2016, “Fair share. Reclaiming power in the sharing economy”. Retrieved on: https://medium.com/rsa-
reports/fair-share-reclaiming-power-in-the-sharing-economy-499b46bd4b00#.a95g35stt 
110 http://rachelbotsman.com/thinking/ 

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Table 37: Peer review and reputation systems 

Platform 

Sector 

Airbnb 

Sharing/Renting 
Accommodation 

BlaBlaCar 

Sharing/Hiring 
Ride 

easyCar 
Club 

Sharing/Renting 
Goods 

eBay 

Nimber 
Peerby 

Uber 
Poop/Pool 

Wallapop 

(Re)Sale of 
goods 

Odd Jobs 
Sharing/Renting 
Goods 
Sharing/Hiring 
Ride 

(Re)Sale of 
goods 

Wimdu 

Sharing/Renting 
Accommodation 

Yoopies 

Odd Jobs 

Reputation system 

Peer profile 
badge  
X 

Peer feedback - 
rating system 
X 

Peer 
review 
system 
X 

Monitoring of reviews  

Before 
publication 

After 
publication 
X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

Notes 

It  is  not  clear  if  there  is  a  monitoring 
system  in  place  or  the  platform  relies  on 
peers to signal inappropriate reviews. 
BlaBlaCar  monitors  feedback  before  they 
are released on the platform, as specified in 
the FAQ.  
The  platform  monitors  all  reviews  before 
publication.    On  EasyCar  club  negative 
feedback is required before a complaint can 
be made. 
It  is  not  clear  if  there  is  a  monitoring 
system  in  place  or  the  platform  relies  on 
peers to signal inappropriate reviews. 
Does not specify if reviews are monitored.  

n/a 

Peer  providers  can  be  deactivated  if  their 
rating  falls  below  the  minimum  rating, 
which varies for each city 111  
 Wallapop  has  a  moderation  team  which 
monitors peer user activities  including peer 
reviews. 
It is no clear if there is a formal monitoring 
system  in  place  of  the  platform  replies  on 
peers to signal inappropriate reviews. 
Reviews  are  monitored  after  publication 
through keyword search. 

Source: VVA analysis of Task 4 case studies 

111 Uber specified that deactivation applies in the EU but there is no publicly available information on rules governing deactivation of users.   

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The  following  practices  were  identified  in  how  platforms  manage  review  and  rating 
systems:  

  All  the  platforms  that  allow  peers  to  leave  reviews  to  other  peers  (except  for 
Nimber  that  does  not  specify),  reserve  the  right  to  delete  reviews  if  they  do  not 
respect certain standards (i.e. use of violent/vulgar language). 

  Three  platforms  award  reputation  badges  rewarding  peers  for  their  positive 

performance or activity on the platform. These are: 

o  BlaBlaCar’s “experience levels” assess the frequency and the quality of the 

platform’s use by the peer.  

o  Airbnb has a badge that distinguishes “Super Hosts” for the quality of the 

services they provide on the platform.  

o  eBay  gives  badges  for  peer  providers  offering  “Top-rated”  or  “Premium 

Service”  

  Two  out  of  eight  platforms  (BlaBlaCar,  easyCar  Club)  monitor  all  reviews  before 
publication.  Yoopies  and  Wallapop  monitor  and  control  user  reviews  through  a 
keyword  search  after  reviews  are  published,  while  the  other  platforms  (AirBnb, 
eBay,  Wimdu)  appear  to  rely  on  peers  to  signal  unfair,  incorrect  or  fraudulent 
reviews. 

  None  of 

the  platforms  provides 

information  about 

the 

reliability  or 

representativeness of user reviews or ratings.  

  Some  platforms  state they use  ratings  or  reviews  to  promote or  relegate listings 
in the search results (AirBnb). Other platforms do not inform users if and/or how 
positive or negative reviews influence the search results.  

  On Uber, peer providers can be deactivated if their rating falls below a minimum 
rating,  which  varies  for  each  city.  Uber  alerts  peer  providers  if  their  rating  is 
approaching  the 
information  about  quality 
limit,  and  gives  them 
improvement courses. Peer providers are deactivated after multiple notifications. 

lower 

  BlaBlaCar’s  “two-way  review  system”  means  that  the  platform  does  not  disclose 
user  feedback  until  both  peers  have  reviewed  each  other,  or  until  14  days  have 
passed112. The peer consumer’s review about the driver’s ability is anonymous, to 
encourage honesty and reduce fear of retaliation113. 

To  conclude,  although  review  and  rating  systems  are  a  key  trust  building  tools,  a  large 
minority of platforms do not offer such systems. Among the case study platforms, most 
do, but they often do not clearly explain how these systems are monitored and managed, 
and how they are used in search results.  None of the platforms give information to users 
about  the  representativeness  and  reliability  of  user  reviews  or  ratings,  although  they 
dispose of the data to establish the percentage of transactions that are reviewed and the 
frequency of fake or fraudulent reviews. 

7.3  Platform practices regarding pre-screening and identity verification  

In  addition  to  peer  reviews,  ratings  and  reputation  systems,  identity  verification  is 
another  resource  available  to  platforms  to  create  trust  among  users.  The  screening  of 
485 platforms found that 25% of platforms carry out some form of check of user data or 

112 BlaBlaCar case study reports, section 2.4.1. 

113 BlaBlaCar case study report, section 2.4.1. 

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identity  information.  The  nature  of  these  checks  and  their  thoroughness  varies 
significantly across platforms as shown by case studies and the Legal Analysis. 

The  review  of  the  Terms  and  Conditions  of  the  P2P  platforms  screened  for  Task  5114 
highlighted  two  main  systems  for  the  platform  to  check  the  user  information  when 
registering to gain access to transacting on the platform: 

  Sending a verification email (usually during the registration process): the platform 
sends an email to the email address provided by the user and asks him to confirm 
that  he  revealed  his  email  address  for  the  purpose  of  registration  with  the 
platform; and/or 

  Registering  with the platform through social  media or services offered by Google 
or  Facebook.  Instead  of  filling  in  an  online  registration  form,  registration  can  be 
completed  by  linking  the  user’s  account  to  an  existing  social  media  profile. 
Consequently, the basic information available in the social media service, such as 
user’s  identity  and  personal  contact  information,  is  directly  transferred  to  the 
platform. 

It further finds that most national platforms have no mechanisms to actively verify that 
the  information  provided  by  their  users  as  well  as  their  personal  data  are  truthful  and 
reliable.  But  some  national  platforms  have  stricter  (optional  or  obligatory)  verification 
procedures  for  peer  providers:  these  include  CarAmigo  (BE)  115,  Guloggratis116  (DK)  
Tradera,117  (SE)  or  Osta118  (EE),  Elderhomeshare  (EI),  119  Hassle120  and  Trusted  House 
Sitters121 (UK) , and Jobado and Helping (NL) 122.  

The  case  studies  show  that  two  sharing/hiring  ride  platforms  (Uber  and  easyCar  Club) 
carry  out  a  pre-screening  of  peer  provider  identity  during  the  registration  process,  by 
verifying  the  authenticity  of  identity  and  car  registration  documents  and  by  checking 
criminal  records.  Wimdu  checks  out  peer  providers  through  phone  calls  and  occasional 
visits.  But  most  platforms  explicitly  deny  responsibility  for  the  accuracy  of  identity 
information of peers in their T&Cs (e.g. Airbnb, eBay, Nimber, Peerby Classic, BlaBlaCar, 
Yoopies, Wallapop).   

The  table  below  provides  a  summary  of  the  current  practices  of  the  10  case  study 
platforms in terms of pre-screening and identity verification. 

114 Task 5 report, section 4.2.2. 
115 CarAmigo website, available at: https://www.caramigo.be/img/cgu/CGU-Caramigo-FR.pdf. Belgian platform 
for the sharing of carpooling and ride sharing activities. 
116 ‘Terms and conditions’, Guloggratis website available at http://www.guloggratis.dk/sider/brugerbetingelser. 
Danish platform facilitating the (re)sale of new and used/second-hand goods. 
117 Tradera homepage regarding liability available at http://info.tradera.com/sakerhetscenter/anvandaravtal/. 
Swedish platform facilitating the (re)sale of new and used/second hand goods). 
118 Terms and conditions Osta.ee, available at: https://osta-
ee.postimees.ee/index.php?fuseaction=support.page&id=1048. Estonian platform for the sale or (re)sale of 
new and used/second hand goods). 
119 ‘Terms and conditions’ Elderhomeshare website available at http://www.elderhomeshare.ie/#!garda-
vetting/c24ze. Irish platform for sharing of private accommodation.  
120 Hassle website available at https://hassle.com/uk/apply (non-professional services). 
121 Website available at https://www.trustedhousesitters.com/gb/ (non-professional services). 
122 They are both platforms offering non-professional services. Jobado website, available at 
https://www.jobado.nl/algemene-voorwaarden; and Helping website, available at 
https://www.helpling.nl/algemenevoorwaarden.  

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Table 38: Pre-screening of peers and identity verification   

Platform 

Sector 

Airbnb 

Sharing/Renting 
Accommodation 

Pre-screening 

Verification 
of identity 
documents 

Optional 

Criminal 
record 
check 

User 
information 
checks (through 
email or social 
media) 
X 

BlaBlaCar 

Sharing/Hiring 
Ride 

Optional  

easyCar 
Club 

Sharing/Renting 
Goods 

X 

X 

eBay  

Nimber 

Peerby 

Uber 
Pop/Pool 

(Re)Sale of goods 

Odd Jobs 

Sharing/Renting 
Goods 
Sharing/Hiring 
Ride 

Wallapop 

(Re)Sale of goods 

Wimdu 

Sharing/Renting 
Accommodation 

X 

X 

Yoopies 

Odd Jobs 

Optional 

Optional  

Source: VVA analysis of Task 4 case studies 

X 

X 

X 

X 

X 

X 

X 

X 

X 

Notes 

 

 

Verification of email and of mobile number (optional) and possibility to connect to 
social media profile  
Peers can submit a copy of the identity document such as passport, it can also be 
requested by peer providers  

  Optional “Verified ID” badge for peers that submit a certain amount of information  
Verification of email and mobile number (optional) and possibility to connect to 
 
social media profile  

  Optional verification of identity document/driving license in France and the UK only  
 
 
 

Verification of email and possibility to connect to social media profile  
Verification of identity document and criminal record checks 
Verification of car registration and driving license and proof of residence by cross-
checking with insurance databases, MOT, government open data, and electoral 
roll.  
Video calls to verify the peer identity 
Verification of email 

Verification of email and mobile number and possibility to connect social media 
profile 
Verification of email and possibility to connect to social media profile 

 
 
 

 

Procedure varies between countries. 
Verification of peer provider identity document and criminal record checks 
Verification of email and possibility to connect to social media profile 
Phone number and payment method needed during the registration process 
Verification of email and possibility to connect social media profile 

 
 
 
 
 
 
 
  Wimdu employees occasionally visit properties in person 
 
  Optional verification of identity document, criminal record and qualifications by 

Verification of email and possibility to connect to social media profile 
Peer provider receives a personal phone call when adding a listing 

Verification of email and possibility to connect to social media profile 

platform to obtain the “verified” badge 

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In the sharing/hiring Ride sector, systematic pre-screening is more likely (easyCar Club, 
Uber). In (re)sale and sharing/renting goods sectors, verification of information is limited 
to  basic  user  information  checks.  Sharing/renting  accommodation  and  odd  job  sectors 
present a more mixed picture with some platforms offering non-mandatory verification of 
ID documents (Airbnb, Yoopies). 

To conclude, platform checks regarding the user identity information submitted by peers 
remain,  in  most  cases,  quite  basic  and  almost  all  platforms  deny  responsibility  for  the 
accuracy  of  user  information.  The  lack  of  adequate  identity  verification  also  raises 
concerns  given  that  often  people  meet  face-to-face,  geolocation  data  are  exchanged 
among platform users and the other peer may not be identifiable in case something goes 
wrong with the transaction. Appropriate user identity verification also is a key element in 
ensuring the authenticity of user reviews.  

Furthermore,  the  results  of  the  screening  of  485  platforms,  the  user  survey  and  focus 
groups,  as  well  as  the  case  studies,  indicate  that  the  core  trust  building  tools,  peer 
review  and  rating  systems  as  operated  by  most  platforms  and  their  identity  verification 
practices,  are  neither  fully  reliable  nor  transparent.  Their  effectiveness  is  therefore 
subject to serious doubt.  

7.4  Cross-platform portability of reputations and identity verification  

A  general  issue  of  peer  review  and  ratings  and  identity  verification  systems  is  their 
portability across platforms.  

As  highlighted  by  consumer  associations,  peers  build  their  “reputation  capital”  on  each 
platform  gradually  as  they  use  them,  but  most  of  the    time  cannot  transfer  this 
reputation  to  another  platform.123  This  lack  of  portability  is  problematic  for  several 
reasons.  First,  it  can  become  a  disincentive  for  peers  to  change  platforms  (“lock-in” 
effect),  restricting  consumer  choice  and  hindering  competition  between  platforms.124 
Secondly, it can make it more difficult to identify peer providers or peer consumers with 
bad  ratings  or  reviews  as  they  can  build  new  reputations  from  scratch  every  time  they 
change platform.125  Third,  it  also raises  questions  of  data  ownership  when  peers  do not 
have access to use of their reputation data as they wish.126  

There are a number of initiatives aiming to facilitate online reputation portability. Several 
platforms such as Traity, Deemly or Trust Cloud have been set up to enable consumers 
to  create  “reputation  passports”  127.  They  rely  on  algorithms  that  collect  data  from 
several  platforms  about  the  peer’s  interactions  with  other  peers.  For  instance,  Deemly 
calculates  a  score  out  of  the  peer’s  ratings  and  reviews  on  different  platforms.  During 
registration,  the  platform  asks  users  to  log  into  the  platforms  where  they  are 
registered128, to access their ratings and reviews, and at least one social media platform 
to verify their identity. The Deemly profile score can be used across platforms as proof of 
reliability. The collection and use of personal data is controlled by the platform’s Privacy 
policy, which states that the user’s information is encrypted and will not be sold to third 
parties.129  

123 OCU et al, 2016, “Collaboration or business? Collaborative consumption: from value for users to society with 
values”, p. 12.  
124 BEUC, 2016, Position Paper on the Collaborative Economy, p. 9 
125 OCU et al., op. cit., p. 12. 
126 Balaram, op. cit.  
127 http://www.fastcompany.com/1747551/sharing-economy   
128 Platforms covered include Airbnb, GoMore, TrendSales, Upwork, Laer Noget NYT, and Yelp. 
129 http://deemly.co/faq/#worriedprivacy  

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Some countries have developed public identity verification systems. For example, in the 
UK GOV.UK Verify gives citizens access to online government services, and may make it 
accessible to others, possibly including P2P platforms.130 Since May 2015, Estonia offers a 
transnational  digital  identity  (“e-Residency”).131  Applicants  complete  an  online  form, 
upload a photo and a copy of an ID document. Their identity is verified in a face-to-face 
meeting, during which fingerprints are collected. In France, public authorities accredited 
the  third-party  platform  Wethic  to  verify  the  authenticity  of  user  reviews.  This  system, 
described  as  a  compromise  between  public  enforcement  and  self-certification,  could 
constitute a third approach to identity verification.132 

While  these  initiatives  are  a  first  step  to  help  peers  control  the  use  of  their  reputations 
and identity data,133 they have limited outreach to date and it is unclear to what extent 
bigger platforms would have an incentive to participate in such schemes.134  Scholars and 
consumer  organisations135  have  advocated  a  legal  right  to  data  portability,  i.e.  the 
possibility for users to transfer their personal data to different online platforms.  

To  conclude,  issues  related  to  cross-platform  portability  of  reputations  and  identity 
verification are complex, raise sensitive privacy and security issues, and involve multiple 
stakeholders, 
including  public  authorities.  Current  approaches  to  cross-platform 
portability  are  very  diverse  across  (P2P)  platforms  and  countries,  and  likely  to  be  in 
many  cases  still  under  development.  The  development  of  these  tools  is  nevertheless 
important  as  it  may  contribute  to  solving  issues  regarding  peer  review,  ratings, 
reputations and information on peer identity. 

130 https://www.gov.uk/government/publications/introducing-govuk-verify/introducing-govuk-verify 
131 https://e-estonia.com/e-residents/about/ 
132 https://www.wethic.fr/ 
133 Balaram, 2016. 
134 Smichowski, B., 2016, “Data as a common in the sharing economy: a general policy proposal”, p.17. Retrieved: 
https://hal.archives-ouvertes.fr/hal-01386644/document  
135 Smichowski, op. cit., BEUC, op. cit.  

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8  Access  to  complaints,  redress  and  insurance  on  P2P 

platforms 

8.1  Peer experiences in addressing problems on P2P platforms 

This  section  discusses  how  peers  and  platforms  address  the  problems  encountered  on 
P2P platforms, whether the problems are resolved, by whom and how.  

When confronted with problems, peer consumers and peer providers reacted differently: 
Almost half of peer consumers (46%) did not take any actions to resolve the problems. 
The main reason for not taking any action was that the amount of money involved was 
too small or that it would involve too much time and effort. When they did take actions, 
most complained to the other peer (30%) or gave a low ranking or wrote a bad review 
(20%), while 17.5% complained to the platform. 

Table 39: Consumer actions when problems occur 

Complained 
to other 
peer 

Appealed 
to 
platform 

Appealed to authority 
or consumer 
association/institution 

Did not 
take 
action 

Gave 
low 
ranking 
or bad 
review 

20,4% 

Peer 
Consumers 
Peer 
Providers 
Source:  Task  2  survey,  Base:  Peer  consumers  (N=4626)  and  peer  providers  (N=1187)  who  experienced  at 
least one problem  

17,5% 

22,8% 

34,1% 

29,8% 

28,5% 

35,6% 

46,4% 

7,9% 

4,8% 

Taking action increased their chances of achieving a satisfying solution:  45% to 60% of 
all  peer  consumers  that  took  action  saw  all  or  most  of  their  problems  resolved.  This  is 
particularly  likely  when  addressing  this  problem  with  the  other  peer  (61%),  but  a 
considerable proportion of consumers also achieved solutions via the platform (45%) or 
by  getting  their  payment  back  from  the  payment  service  provider  (46%).  However,  a 
large proportion of peer consumers that tried to solve the problem through the platform 
or payment service provider achieved no problem solution (42% for both).  

Problems on (Re)Sale platforms are relatively less likely to get resolved by the involved 
peers,  the  platform  and  the  payment  service  providers  than  problems  on  collaborative 
platforms. Across the different sectors of collaborative sectors, problems are most likely 
to be solved on Sharing/Renting Goods and Odd Jobs platform. 

Table 40: Actions the platform has taken in response to the problem 

Actions the platform has taken in response to the problem 

Acknowledged the problem 
Investigated the problem 
Gave a satisfactory explanation 
Gave an unsatisfactory explanation 
Gave a partial refund 
Gave a full refund 
Gave a credit/note or voucher 
Gave compensation for damage/losses 
Has done nothing 
Other 
Don’t know 
Source: Task 2 survey; Base: Peer consumers who took action after experiencing a problem by contacting the 
other platform (N=812) 

Collaborative 
sectors 
32,9% 
35,7% 
36,4% 
20,9% 
27,5% 
20,9% 
12,0% 
10,5% 
3,1% 
0,4% 
2,3% 

(Re)Sale of 
goods 
34,8% 
42,8% 
26,2% 
12,1% 
7,2% 
35,2% 
5,1% 
4,2% 
12,3% 
3,2% 
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In most cases the other peer or the platform solved the problem by offering a refund, or 
another form of financial or other compensation (53,2% from peers, 58% for platforms).  
Full refunds are more likely to be achieved from (re)sale of goods than from collaborative 
platforms.  Problems  were  less  likely  to  be  resolved  by  the  other  peer  on  shared/rented 
accommodation  platforms  than  on  other  platform  sectors.  Finally,  two  thirds  of  peer 
consumers  are  (very)  satisfied  with  how  the  other  peer  or  platform  dealt  with  their 
complaint.  

Table 41: Satisfaction with how the other peer dealt with your complaint (Peer 
consumers) 

Neutral 

Satisfied 

Very 
satisfied 
15,2% 

Satisfaction with how the other 
peer dealt with your complaint 
Peer consumers 
Satisfaction with how the 
platform dealt with your 
complaint 
Peer consumers 
Peer providers 
For satisfaction with the other peer: Base Peer consumers whose problems were addressed by the other peer 
(N=1270);  For  satisfaction  with  the  platform:  Base  Peer  consumers  (N=596)  and  peer  providers  (N=405) 
whose problems were addressed by the platform 

Not at all 
satisfied 
2% 

Not 
satisfied 
7,2% 

Not at all 
satisfied 

Very 
satisfied 

Not 
satisfied 

22,8% 
28,9% 

5,4% 
13,8% 

46,6% 
33,8% 

23,8% 
15,3% 

1,3% 
8,1% 

Satisfied 

Neutral 

24,3% 

51,3% 

Most  peer  providers  who  experienced  a  problem  took  action  to  solve  their  problem  by 
complaining to the other peer (36%) or by appealing to the platform (34%). Only 29% of 
them  did  nothing,  mostly  because  they  believed  that  they  were  unlikely  to  get  a 
satisfactory  solution.  Addressing  the  problem  with  the  platform  is  positively  related  to 
achieving a satisfying outcome. Also, as opposed to what was found for peer consumers, 
leaving  a  negative  review  or  rating  actually  helps  peer  providers  to  have  the  platform 
solve  the  problem.  Finally,  only  half  of  the  peer  providers  are  satisfied  with  how  the 
platform  dealt  with  their  complaint  (49%  satisfied),  which  is  considerably  less  than  for 
consumers (70%). 

Focus group results gave indications that complaining to the platform depends to a large 
extent  on  the  direct  accessibility  of  the  platform  by  phone  or  email.  Respondents  also 
found that solving a problem involves quite a lot of hassle and does not necessarily lead 
to a (satisfying) solution.  

8.2  Platform practices regarding complaints, redress and insurance 

Among  the  485  P2P  platforms  screened  within  the  scope  of  this  research,  52%  offer  at 
least some level of complaints handling, and 24% of offer insurance (either as part of the 
transaction  or  as  add-on)  for  their  product/service  to  either  peer  consumer  or  peer 
provider.  

8.2.1  Complaints and redress 

Table 42 summarizes the complaints channels and redress policies found on the 10 case 
study platforms. 

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Table 42 : Access to complaints and informal redress by the platform  

Complaints 

Redress 

Platform 

Q
A
F

l
i

a
m
E

t
a
h
C

e
n
o
h
P

X 

X 
X 

X 
X 
X 
X 
X 

X 
X 
X 
X 
X 

X 
X 
X 
X 
X 

Airbnb 
BlaBlaCar 
easyCar Club 
eBay 
Nimber 
Peerby/Peerby 
Go 
Uber Pop/Pool 
Wallapop 
Wimdu 
Yoopies 
Source: VVA analysis of case study platforms  

X 
X 
X 
X 

X 
X 
X 
X 

X 

X 

X 

X 

X 

y
c
i
l

o
p

n
r
u
t
e
R

X 

y
c
i
l

o
p

d
n
u
f
e
R

X 
X 
X 
X 

X 

X 

n
o
i
t
a

l
l

e
c
n
a
C

y
r
a
t
e
n
o
M

s
e
i
t
l
a
n
e
p

s
e
t
a
d
e
M

i

s
e
t
u
p
s
i
d

n
e
e
w
t
e
b

s
r
e
e
p

X 

X 
X 

X 

X 

y
c
i
l

o
p

X 
X 
X 
X 

X 

X 

X 
X 

All  ten  platforms  offer  some  form  of  channel  for  complaints,  mainly  via  online  means, 
ranging from a general email address (Nimber) to electronic complaint forms and instant 
online  messaging  systems.  Five  out  of  ten  platforms  can  be  reached  by  phone.  All 
platforms also provide peers with a FAQ section where advice is given about what to do 
to solve problems. However, guidance in the FAQ on what to do in case something goes 
wrong with the delivery of the product or performance of the service is available only on 
five platforms (easyCar Club, Airbnb, eBay, BlaBlaCar and Wimdu).  

Yoopies, Wallapop, Nimber and Peerby do not give any information about how complaints 
or  refunds  are  managed.  Several  platforms  manage  “redress  policies”  and  actively 
intervene  to  remedy  problems  with  the  transaction.  But  none  of  the  platforms  sets  out 
clearly  the  responsibility  they  assume  for  handling  complaints  in  case  something  goes 
wrong.  In  case  of  the  most  common  problems  with  the  transaction  (poor  quality  of  the 
good or service, or not as described) refunds are issued at the discretion of the platforms 

Most  platforms  do  not  explain  to  peers  how  refunds  are  decided.  Only  three  platforms 
explain their rules for refunds:  

  Airbnb  and  Wimdu  have  refund  policies  that  may  entitle  peer  consumers  to 
refunds in case they do not have access to the property, if the property booked is 
not as described or – in the case of Airbnb - not clean or safe.   

  eBay has clear rules on refunds, replacements and exchanges for sales by private 
peer  providers  if  the  item  has  been  paid  with  PayPal,  debit  or  credit  card,  this 
includes a money back guarantee in case items sold by private peer providers are 
not received or not as described. 

Rules for refunds in case of cancellations and cancelltion fees are set by the platform in 
function of the time period before the agreed delivery of the good or service: 

  Airbnb and Wimdu impose rules on peer providers for cancellations of bookings by 
peer consumers. These rules determine the right to a full or partial refund of the 
rental  price,  and  the  “cancellation  fees”  due  to  the  platform,  equivalent  to  the 
transaction  fee.  Peer  providers  can  choose  between  a  longer,  medium  length  or 
shorter period before the date of the booking for giving full or partial refunds.  
  Airbnb  and  Wimdu  also  set  rules  for  cancellations  by  peer  providers.  Peer 
consumers  are  fully  reimbursed,  or  have  the  possibility  to  book  alternative 
accommodation.  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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  On easyCar Club both peers can withdraw without penalties up to 72 hours before 
the start of the rental period. In case of peer provider withdrawal, peer consumers 
are fully reimbursed. If a peer consumer or provider cancels the booking less than 
72  hours  before  the  rental  period,  the  platform  charges  them  a  cancellation  fee 
that varies depending on the timing of the cancellation. 

  Uber  gives  peers  the  right  of  cancellation  within  5  minutes  after  the  driver  has 
accepted  the  ride  (if  the  provider  cancels),  or  5  minutes  after  the  request  has 
been  sent  by  the  peer  consumer  (if  the  peer  consumer  cancels).  After  this 
timeframe, the platform charges a cancellation fee – the amount is not specified.  
  On  BlaBlaCar,  when  a  peer  consumer  cancels  a  ride,  the  platform  charges  a 
cancellation  fee.  For  cancellations  done  more  than  24h  before  departure  the 
cancellation  fee  is  equivalent  to  the  transaction  fee  paid  at  the  time  of  booking. 
For cancellations made less than 24h before departure, the platform refunds 50% 
of  the  price  of  the  ride  minus  the transaction fee.  The  platform does  not  issue a 
refund if the cancellation occurs after departure or if the peer consumer does not 
show up. When a peer provider cancels a ride, the peer consumer is  reimbursed 
fully, including the transaction fee. 

To  conclude,  almost  half  (48%)  of  the  485  platforms  screened  have  no  complaints 
handling  services.  Case  study  platforms  offer  all  at  least  electronic  complaint  channels 
and  FAQ  sections,  but  guidance  on  what  to  do  in  case  something  goes  wrong  with  the 
delivery of the product or performance of the service between the peers is only available 
on  five  platforms  (easyCar  Club,  Airbnb,  eBay,  BlaBlaCar  and  Wimdu).  None  of  the 
platforms sets out clearly the responsibility they assume for handling complaints in case 
something goes wrong. In case of the most common problems with the transaction (poor 
quality of the good or service, or not as described) refunds are issued at the discretion of 
the platforms. 

8.2.2  Access to insurance 

Most of the platforms analysed (except Yoopies, Wallapop and Peerby) include insurance 
for damages covering peer providers in the transaction fee. Table 43 shows a summary 
of insurance covers available on 10 case study platforms. 

Table 43: Availability of insurance across 10 platforms  

Platform 

Airbnb 

Insurance 

Included in 
transaction  

Add-on 
service 

BlaBlaCar 
(transaction 
model)  

eBay 
easyCar 
Club 

Nimber 

Peerby 
Classic 
Peerby Go 

X 

X 

X 

X 

n/a 

X 

Notes 

Insurance only covers peer providers 

 
  Host Guarantee: coverage against damages by guests 
  Host Protection Insurance: coverage against claims by. 

guests or third parties for injuries or damage. 

  Available only in FR, DE, IE, IT, NL, PT, ES and the 

 

UK. 
Insurance covers both peer providers and peer 
consumers 

  Breakdown cover & onward travel 
  Personal accident cover 
  Legal protection 
n/a 
  Admiral motor insurance covers the peer provider’s car 
for  the  time  of  the  rental  against:  loss,  damage,  fire, 
theft, third party liability and breakdown 

  The platform states to cover the parcel from damages, 

but no detailed information is provided. 

n/a 

n/a 

 

Insurance or "Warranty" included in the transaction fee 
covers the repair or replacement of the good rented 
item in case of damages. 

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Platform 

Uber 
Pop/Pool 
Wallapop 
Wimdu 

Insurance 

Included in 
transaction  

Add-on 
service 

X(UberPop)  

n/a 

X 

n/a 

X 

Yoopies 
Source: VVA analysis of case studies  

n/a 

n/a 

Notes 

  Liability insurance for UberPop peer providers covering 

property damage and bodily injury to peer consumers 
and third parties 

n/a 
 

Insurance coverage for peer providers against damage 
caused by peer consumers 

  Add-on optional travel insurance for peer consumers in 

Germany and Spain against payment136 

n/a 

The scope of insurance coverage varies between platforms and sectors.  

  BlaBlaCar  offers  extensive  insurance  protecting  both  peer  provider  and  peer 

consumers.  

  There  is  a  lack  of  detail  on  the  insurance  cover  included  in  the  price  on  Airbnb, 

Uber, easyCar Club, and Wimdu.  

  There  is  no  information  regarding  the  scope  of  the  cover  and  how  validity  of 

claims is assessed.  

  On  Nimber  there  is  a  general  lack  of  information  and  detail  on  the  included 

insurance cover  

  Wallapop  (resale),  eBay  (resale)  and  Yoopies  (odd  jobs)  do  not  offer  any 

insurance to either the peer provider or peer consumer.  

To conclude, about one quarter of 485 platforms screened offer some form of insurance, 
either as part of the transaction fee or as an add-on service to either peer consumer or 
peer provider. Case study platforms in the accommodation sector and ride sharing/hiring 
sector  and  sharing/renting  of  goods  sector  offer  insurance  coverage  mainly  to  peer 
providers  against  damages  to  the  rented  property,  car  or  goods.    The  main  issue  with 
insurance  cover  provided  by  the  P2P  platforms  analysed  for  this  study  is  the  lack  of 
information on what is covered and how the validity of claims is assessed 
. 

136 No further information is provided on the website and no interview could be conducted with the platform. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
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9  Regulatory elements in P2P platform practice  

individuals  acting 

This Section analyses the EU consumer acquis and Member States’ legislation applicable 
to C2C transactions and online platforms facilitating P2P transactions. A focal point of this 
analysis  is  the  identification  of  the  key  national-level  indicators  used  to  distinguish 
in  a 
between 
commercial/professional  capacity.  Furthermore,  the  Legal  Analysis  investigates  the 
extent to which the EU consumer acquis and other relevant EU legislation might apply to 
C2C transactions and online platforms facilitating these transactions. It also identifies the 
main  enforcement  issues  of  the  applicable  legal  frameworks,  the  problems  experienced 
by  national  authorities,  and  relevant  legal  and  policy  initiatives  adopted,  or  being 
discussed, by Member States or at EU level.  

in  a  private  capacity  and 

individuals  acting 

The  transactions  covered  by  the  Legal  Analysis,  are  those  concluded  by  peers137  and 
facilitated by online platforms that charge a certain type of fee, as part of the price or as 
any other compensation to the platform in the sectors under study. 

9.1  The nature of the transaction 

Distinguishing  between 
in  a 
commercial/professional capacity and individuals acting in a private capacity is essential 
to determine whether consumer law and marketing law applies.  

traders  and  consumers,  between 

those  acting 

9.1.1  EU legal framework  

EU  legislation  does  not  expressly  clarify  the  distinction  between  B2C  and  C2C 
transactions.138 The European Commission’s Communication of 2 June 2016,139 however, 
identified  three  main  elements  to  help  assess,  on  a  case-by-case  basis,  whether  an 
individual  is  acting  as  a  private  individual  or  as  a  business.  These  criteria  are  the 
frequency of the services, the profit-seeking motive and the level of turnover.  

A  paper  by  the  Organisation  for  Economic  Cooperation  and  Development  (OECD) 
suggests  additional  factors  that  could  be  taken  into  account  in  order  to  distinguish 
between B2C and C2C transactions: the level of organisation and planning of the activity; 
the  value  of  the  transaction;  the  duration  of  the  activity  and  the  impression  to  the 
outside world.140  

9.1.2  National regulatory approach 

Member  States  provide  statutory  definitions  of  ‘consumer’  (or  ‘non-professional’)  and 
‘trader’  (or  ‘professional’,  ‘business’,  ‘entrepreneur’)  in  different  areas  of  law.  The 
definitions  found  in  national  consumer  law  reflect  those  provided  by  the  EU  consumer 
acquis.  In  addition,  national  Commercial  Codes  also  typically  set  out  the  notions  of 
‘trader’  and  ‘acts  of  trade’.  Although  the  terminology  used  by  different  national  legal 
instruments  is  not  always  completely  uniform,  definitions  of  ‘trader’  and  ‘consumer’  are 
substantively equivalent.  

137 ‘Peers’ means both peer suppliers/providers and peer consumers. The term ‘peers’ generally covers 
individuals acting in a private capacity.  
138 Communication from the Commission to the European Parliament, the Council, the European Economic and Social 
Committee  and  the  Committee  of  the  Regions,  ‘A  European  agenda  for  the  collaborative  economy’,  2.6.2016,  COM 
(2016) 356 final, p. 5. 
139 Ibid. 
140 Organisation for Economic Cooperation and Development (OECD), ‘Protecting consumers in peer platforms market: 
exploring  the  issue’,  Draft  Background  Paper  for  Panel  3.1  of  the  2016 Ministerial  on  the  Digital  Economy,  29  March 
2016, DSTI/CP(2015)4/REV1, p. 18. 

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Indicators set by national instruments 

National  regulatory  approaches  to  indicators  of  what  constitutes  a  trader  or  relevant 
circumstances for determining this, in the field of consumer rights and in other areas of 
law,  differ  from  one  Member  State  to  another,  and  from  sector  to  sector.  Although 
Member  States’  approaches  are  different  and  fragmented,  the  ‘continuity’  and  the 
‘professional nature’ of the activity are the two main elements on basis of which Member 
States  assess,  on  a  case-by-case  basis,  whether  an  individual  is  acting  in  a  private 
capacity or as a trader (see Section 3.1.2 of Task 5 Report). Another indicator taken into 
account  by  all  Member  States  is  the  economic  purpose  of  the  activity.    The  ‘continuity’ 
and the ‘professional nature’  are assessed against indicators that in most Member States 
are  defined  in  non-legislative  instruments  (policy  documents,  case  law)  or  enforcement 
practice, and in some Member States in national legislation.  

In most Member States the ‘continuity’ of the activity is assessed based on the number, 
amount  and  frequency  of  the  transactions  carried  out.  ‘Professional  capacity’  is  usually 
assessed against the profit-seeking motive or the turnover generated by the activity.  

Tax thresholds and sector-specific thresholds 

Some  Member  States  have  developed  sector-specific 
thresholds  distinguishing 
professional  activities  from  non-professional  activities  that  determine  whether  sector 
specific  legislation  applies.  Some  other  Member  States  have  set  tax  thresholds  to 
distinguish businesses from private individuals for tax purposes.  

Tax thresholds are, for example, set by national legal instruments in Latvia, France, and, 
potentially, in Belgium, and in the Netherlands and Sweden by policy rules. For example, 
in France – since 2016, the status of ‘micro-entrepreneur’ can be granted to sole traders 
who do not exceed certain turnover thresholds.  

Sector  specific  thresholds  are  mostly  found  in  the  accommodation  sector.  Cities  and 
regions in several Member States (Spain, Italy, the Netherlands and the United Kingdom) 
apply  temporal  thresholds  for  distinguishing  touristic  accommodation  service  activities 
carried  out  by  businesses  from  those  conducted  by  private  individuals  on  an  occasional 
basis.,  In  Italy,  while  some  Regions  refer  to  the  notions  of  activity  carried  out 
‘occasionally’  or  ‘continuously’  (Regional  Law  27/2015  of  Lombardia,  and  Regional  Law 
42/2000  of  Tuscany),  other  Regions  have  introduced  specific  temporal  thresholds  for 
each category of non-hotel accommodation (Regional Regulation 8/2015 of Lazio).  

Such tax and sector specific thresholds, however, are set for specific purposes. They are 
not necessarily  relevant  for distinguishing  consumers from traders in  consumer  law  and 
do not necessarily make consumer law applicable.  

9.2  Overview of the national legislation applicable in the context of online peer-

to peer platforms 

This Section summarises the national legislation applicable to transactions between peers 
acting  in  an  individual  capacity  (C2C  transactions)  and  the  rules  that  apply  to  online 
platforms facilitating P2P transactions. 

9.2.1  Legislation applicable to C2C transactions  

EU consumer law Directives and national consumer legislation  generally do not apply to 
C2C transactions, but exclusively to B2C transactions.  Both the EU and the national legal 
frameworks  applicable  to  B2C  transactions  were  designed  to  protect  consumers  in  their 
relationship with traders.  

 
 
 
 
 
 
 
 
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In most Member States, the main provisions applicable to C2C transactions falling within 
the scope of this study consist in national Civil Code rules.141 

Horizontal legislation  

The  horizontal  legislation  that  applies  to  C2C  transactions  involving  sale  and  (re)sale 
activities, lease agreements and non-professional services usually includes: general civil 
law  provisions  on  contract  formation,  performance  and  remedies  for  breach,  as  well  as 
specific  provisions  on  the  contracts  of  sale  and  lease,  and  on  the  letting  of  work  and 
industry (see Section 3.2.1 of Task 5 Report).  

The  horizontal  civil  law  provisions  vary  from  one  Member  State  to  another  and  do  not 
provide the same degree of protection as afforded to consumers in B2C transactions. But 
they  include  general  requirements  that  are  relevant  to  C2C  transactions  and  that  could 
have  a  similar  effect.  For  example,  good  faith  clauses  presume  that  the  parties  to  a 
contract  will  act  honestly  and  will  faithfully  perform  their  obligations.  And  it  may  be 
argued  that  certain  information  requirements  within  national  civil  law  provisions  are 
relevant  to  sale  and  (re)sale  of  goods,  and  may  protect,  for  example,  against  hidden 
defects.  Similar  requirements  exist  in  relation  to  contracts  for  the  letting  of  things  or 
works.  These  could  be  relevant  in  the  context  of  the  renting  of  movable  or  immovable 
property  or  the  provision  of  non-professional  services.  In  most  Member  States  with  a 
Civil Code regulating these contracts, for example, the lessor is liable for defects or faults 
of the thing let and must warrant it against defects that prevent or diminish its use.  

This level of protection can be arguably considered sufficient as C2C transactions involve 
parties  who  are  on  an  equal  footing.  When  a  C2C  contract  is  concluded  online  via  a 
platform,  however,  usually  the  parties  do  not  physically  meet  or  the  good  is  not 
physically  present,  and  terms  and  conditions  of  the  contract  may  have  been 
predetermined by one of the parties or the platform. The Legal Analysis, therefore, found 
that  Member  States’  civil  provisions  are  generally  not  tailored  to  C2C  transactions 
concluded  online  via  platforms,  because  national  civil  codes  generally  date  from  before 
the digital age 142 

A  notable  exception  was  found  in  France  where  a  recent  amendment  of  Civil  Code 
(Ordinance No. 2016-131) extends some of the key rights protecting consumers in B2C 
transactions  to  C2C  transactions.  In  particular,  it  makes  rules  on  unfair  contract  terms 
applicable  to  C2C  transactions  if  the  contract  is  an  ‘adhesion  contract’,  i.e.  if  one  party 
imposed its content on the other party. 

Sector-specific legislation  

In  some  Member  States,  specific  laws  regulating  the  transport  and  accommodation 
sectors establish licensing requirements that indiscriminately apply to both B2C and C2C 
transactions  and  can  include  quality  and/or  safety  rules  that  protect  parties  to  C2C 
transactions. This is, for example, the case in Germany where, according to Section 2 of 
the  Passenger  Transportation  Act  every  carrier  offering  transportation  for  remuneration 
to a passenger requires a permit. Similarly, the Malta Travel and Tourism Services Act143 
prohibits any person from running or operating a tourist accommodation service activity 
without a licence.  

In  other  Member  States,  sector-specific  legislation  exclusively  covers  B2C  transactions 
and,  in  some  cases,  establishes  thresholds  that  may  help  distinguish  between 

141 In a few rare cases sector-specific legislation for transport and accommodation services also applies to C2C 
transactions.  

142 See the case-law of the Court of Justice of the European Union – CJEU, reported under Section 11.2). 
143 Chapter 409 of the Laws of Malta, Act XII of 1999 as last amended by Act XXIII of 2009. 

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professional  and  non-professional  services.  Furthermore,  some  EU  cities,  such  as 
Amsterdam,  Berlin  and  Madrid,  have  adopted  special  regulations  applicable  to  C2C 
transactions  facilitated  by  platforms  such  as  Airbnb  and  Uber.  Finally,  in  some  Member 
States  local  or  regional  regulations  apply  to  touristic  accommodation  and  transport 
services, that are relevant to C2C transactions (see Section 3.3.2 of Task 5 Report).  

9.2.2  Legislation applicable to online platforms facilitating P2P transactions 

The national provisions transposing the requirements of EU consumer law Directives such 
as  the  Unfair  Commercial  Practices  Directive  (UCPD),144  the  Unfair  Contract  Terms 
Directive  (UCTD)145  and  the  Consumer  Rights  Directive  (CRD)146  are  relevant  and  apply 
whenever  a  platform  qualifies  as  a  ‘trader’  and  engages  in  B2C  commercial  activities. 
Such  platforms  must  always  comply  with  national  rules  transposing  EU  consumer  and 
marketing  law  in  so  far  as  its  own  commercial  practices  are  concerned.  In  such 
situations, under the UCPD, the platform is required to act with a degree of professional 
diligence,  commensurate  to  its  specific  field  of  activity  and  not  to  mislead  its 
users/consumers by either action or omission.147 

Other  national  rules  applicable  to  online  platforms  facilitating  P2P  transactions  are  the 
provisions  transposing  the  Electronic  Commerce  Directive  (ECD)148  into  national  law. 
Although  the  ECD  does  not  regulate  platforms  comprehensively,  certain  provisions  are 
particularly  relevant:  Article  5  (general  information  requirements  for  service  providers); 
Article 6 (information to be provided in commercial communications); and Articles 14 and 
15  (laying  down,  respectively,  the  liability  exemption  and  the  prohibition  to  impose  on 
service  providers  monitoring  obligations  with  regards  to  information  stored  or 
transmitted).  These  national  provisions  apply  to  the  relationship  between  the  peer  user 
and the platform; certain requirements may be also relevant to the relationship between 
the peers.  

Apart  from  the  legislation  transposing  these  EU  Directives  into  national  law,  most 
Member States have no specific legislation applicable to online platforms facilitating P2P 
transactions. So far, only in Italy and France specific legislation has been proposed. (see 
Section 3.3.1 of Task 5 Report).  

In Italy the proposed so-called ‘Sharing Economy Act’.149 aims regulate sharing economy 
digital platforms by guaranteeing the transparency of their activities, fair competition and 
consumer protection, as well as boosting fiscal equality, the sharing economy market and 
the use of innovation technologies.150  To enhance transparency and accountability of P2P 
platforms  it  charges  the  Italian  Antitrust  Authority  with  approving  and  monitoring 
platforms  policies  and  terms  and  conditions.  In  France,  the  Law  for  a  Digital  Republic 
imposes new obligations and transparency requirements on operators of online platforms 
whose activity exceeds a certain number of connections to be defined by decree (Article 
23(I)). In particular, Article 23 quarter A, c), II imposes on accommodation platforms the 
obligation to check: i. whether the (furnished) apartment that the peer supplier wants to 
rent out through the platform complies with the registration requirements of the French 

144 Directive 2005/29/EC of the European Parliament and of the Council of 11 May 2005 concerning unfair business-to-
consumer commercial practices in the internal market OJ L 149, 11 June 2005, pp. 22–39. 
145 Council Directive 93/13/EEC of 5 April 1993 on unfair terms in consumer contracts, OJ L 95, 21 April 1993, pp. 29–
34. 
146 Directive 2011/83/EU of the European Parliament and of the Council of 25 October 2011 on consumer rights, OJ L 
165, 18 June 2013, pp. 63–79. 
147 UCPD Guidance, 25.5.2016, COM (2016) 320, supra, p. 123. 
148  Directive  2000/31/EC  of  the  European  Parliament  and  of  the  Council  of  8  June  2000  on  certain  legal  aspects  of 
information society services, in particular electronic commerce, in the Internal Market. 
149 Legislative Proposal 3564/2016 ‘Discipline of digital platforms for sharing goods and services and provisions to 
boost the sharing economy’ (Disciplina delle piattaforme digitali per la condivisione di beni e servizi  e disposizioni per 
la promozione dell’economia della condivisione), 27 January 2016, available at 
http://www.makingspeechestalk.com/ch/comment_sea/?id_speech=45. 
150 Article 1(2), Legislative Proposal 3564/2016. 

 
 
 
 
 
                                                 
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Tourism Code; ii. that the apartment is not rented out for more than 120 days per year 
(where the property is the main residence of the lessor).  

9.2.3  Specific issues in platform-peer transactions as identified in the national context  

The  specific  issues  identified  in  the  national  context  with  regards  to  the  relationship 
between  platforms  and  their  users  concern  information  requirements,  requirements 
relating to user reviews, the responsibility of the platform and its obligations towards the 
peers, as well as possible redress mechanisms (see Section 3.3.2 of Task 5 Report).  

 

Information requirements:  

One  of  the  main  issues  concerning  the  relationship  between  platforms  and  their  users 
relates to the lack of transparency in online P2P platforms’ rules and practices. According 
to the national level analysis, most platforms qualifying as ‘traders’ and engaging in B2C 
commercial activities do not comply with some pre-contractual information requirements 
arising  from  the  professional  diligence  duty  set  out  by  Article  5(2)  of  the  UCPD.  The 
European Commission’s Guidance on the Implementation/Application of the UCPD (UCPD 
Guidance),151  clarifies  that  in  order  to  comply  with  such  duty,  platforms  should  adopt 
appropriate  measures  aimed  at  clarifying  to  their  users  with  whom  they  are  concluding 
contracts  on  the  platform.  Consequently,  where  platforms  qualifying  as  ‘traders’  in  the 
meaning of Article 2(b) of the UCPD do not enable their users to clearly indicate that they 
act in a professional/commercial capacity or do not clarify  that consumer protection law 
exclusively applies when the transaction is concluded with a trader, this could represent a 
breach of a due pre-contractual information requirement.  

Such  duty  does  not  entail  a  general  monitoring  obligation  of  all  platforms  towards  their 
users as this could be contrary to Article 15 of the ECD (see below), but the adoption of a 
series  of  appropriate  measures  aimed  at  clarifying  to  their  users  with  whom  they  are 
concluding contracts on the platform itself. 

  Requirements relating to user reviews:  

In  most  Member  States,  the  legislation  applicable  to  online  platforms  facilitating  P2P 
transactions does not impose express obligations for the platform to take action against 
fake  or  misleading  user  reviews  and/or  to  not  omit  negative  reviews.152  However, 
national  rules  transposing  Article  14(1)(a)  and  (b)  of  the  ECD  would  apply  and, 
consequently, the information service provider will be held responsible if, knowing of the 
unlawfulness  of  the  user  review,  did  not  take  the  necessary  steps  to  delete  or  block 
access to this review.  

Furthermore,  if  the  online  platform  provides  information  society  services  to  consumers, 
the  relationship  between  the  platform  and  its  users  will  be  generally  qualified  as  B2C. 
Consequently,  the  national  legislation  transposing  Articles  5,  6  and  7  of  the  UCPD  will 
apply.  Based  on  these  provisions,  the  platform  should  not  mislead  its  users  as  to  the 
origin of the reviews or, in case of a sales contract, to the nature, attributes or rights of 
the  entrepreneur/seller.  The  Legal  Analysis  also  found  that  most  platforms  set  minimal 
identification  requirements  for  registration  and  access  (e.g.  name  and  email  address), 
and  usually  do  not  adopt  adequate  measures  to  verify  users’  identity.  In  line  with  the 
professional  diligence  duty  included  in  Article  5(2)  of  the  UCPD  and  the  transparency 
requirements  set  out  by  Articles  6(1)(b)  and 7(4)(a)  of  the  UCPD,  as interpreted in  the 
UCPD Guidance, platforms’ liability should also extend to adequately ensuring their users’ 
identity.  According  to  the  UCPD  Guidance,  platforms  should  adopt  any  necessary 

151 Commission Staff Working Document Guidance on the Implementation/Application of Directive 2005/29/EC on Unfair 
Commercial Practices, accompanying the document Communication from the Commission to the European Parliament, the 
Council, the European Economic and Social Committee and the Committee of the Regions ‘A comprehensive approach to 
stimulating cross-border e-Commerce for Europe's citizens and businesses’, UCPD Guidance, 25.5.2016, COM (2016) 320, p. 
123. 
152 E.g. Belgium, Bulgaria, Cyprus, Germany, Greece, Italy, Lithuania, Luxembourg, Poland, Portugal, Sweden. 

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‘technical  means  to  verify  the  reliability  of  the  person  posting  a  review,  for  instance  by 
requesting him/her to register’.153. 

In  addition,  many  platforms  establish  the  requirements  for  user  reviews  and  the 
conditions  under  which  users  might  be  banned.  Regarding  the  liability  of  platforms  for 
the  possible  unlawful  nature  of  published  user  reviews,  as  explained  below,  in  certain 
circumstances,  platforms  may  be  responsible  for  the  information  they  store,  including 
user reviews. Furthermore, because of the general good faith principle, platforms should 
refrain  from  publishing  fake  or  misleading  user  reviews.  Indeed,  this  clause  may  be 
interpreted  as  an  obligation  for  platforms  to  take  adequate  measures  to  protect  their 
users  from  any  fake  or  misleading  reviews  posted  on  the  platform,  as  long  as  the 
platform is aware of their existence.154 

  Shared responsibility for non-performance:  

In  most  Member  States,  the  legislation  applicable  to  online  platforms  facilitating  P2P 
transactions does not set up a specific obligation for the platform to share responsibility 
with  the  user  in  case  of  non-performance  or  non-conformity  of  the  performance.  The 
national  level  analysis  shows  that  most  platforms  explicitly  exclude  in  their  Terms  and 
Conditions  any  liability  relating  to  the  contracts  concluded  by  peers,  and  they  often 
specify that the platform is not part of these transactions.  

However,  depending  on  the  extent  to  which  a  platform  ‘intervenes’  in  the  transactions 
concluded by its users, the latter may expect that the platform shares responsibility with 
the  peers  in  case  of  non-performance  or  non-compliance  of  the  performance.  For 
example,  where  the  platform  actively  manages  P2P  transactions  (e.g.  facilitating  trust 
among  peers  by  using  or  suggesting  ID  verification  systems,  managing  user  reviews, 
mediating disputes) or governs them (e.g. setting out pricing or user insurance as part of 
the transaction), it is more likely that its users have the impression that the platform will 
also share a certain degree of liability. However, in most Member States, the applicable 
legal  framework  does  not  set  up  such  obligation  and  only  general  civil  law  rules  on 
contractual and non-contractual liability (tort)155can apply.  

  Obligation to remove suppliers who violate consumer rights:  

In  most  Member  States,  the  legislation  applicable  to  online  platforms  facilitating  P2P 
transactions neither explicitly sets up an obligation for the platform to remove suppliers 
who  violate  consumer  rights,  nor  to  monitor  their  users.  According  to  Article  15  of  the 
ECD, online platforms are not obliged to monitor the information they store, transmit or 
make available when providing information society services, nor are they obliged to seek 
facts  and  circumstances  indicating  conduct  of  illegal  activity.  The  national  legislation 
transposing Article 14 of the ECD may also be relevant as the platform would not be able 
to rely on the liability exemption if it has obtained knowledge or has been informed of the 
unlawful  character  of  the  information  or  has  been  informed  by  a  competent  state 
authority of the unlawful character of the activities of the recipient and did not undertake 
immediate actions to remove or to disable access to that information.  

Finally, it is worth noting that both the national analysis and the case studies found some 
platforms’ in their Terms and Conditions, reserve the right to ban or exclude user profiles 
in the event, for example, of bad behaviour, non-fulfilment of obligations, etc.  

  Redress mechanisms:  

The platform will be contractually liable towards the users according to the terms of the 
contract concluded  between  the  platform itself  and  the  peer supplier  or  peer  consumer, 
as well as on the basis of the mandatory and default rules of contract law (including, for 

153 UCPD Guidance, 25.5.2016, COM (2016) 320, supra, p. 137. 
154 UCPD Guidance, 25.5.2016, COM (2016) 320, supra, p. 54. 
155 The basic principle is that everyone is liable for any damage that occurs through their fault.  

 
 
 
 
 
                                                 
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example, the obligation of the parties to act in good faith). Where the platform qualifies 
as  a  ‘trader’,  the  redress  mechanisms  provided  in  consumer  law  will  be  available  to  all 
peers in case of disputes regarding, for example, defaults in the platform’s services.  

It  can  be  concluded  that,  in  most  Member  States,  the  applicable  legal  remedies  for 
dispute resolution are those provided in the rules of general civil law. These include the 
liability  for  damages  resulting  from  both  contractual  and  extra-contractual  claims  (tort 
law).  

With regards to possible disputes between peers, the one of the main issues could be the 
that  bringing  the  case  to  the  civil  courts  is  generally  the  only  mechanism  available  to 
obtain  redress  in  case  of  disputes.  The  Legal  Analysis  found  that,  however,  such  civil 
claims are very limited. The costs and length of civil proceedings, indeed, could prevent 
parties  to  low-value  C2C  contracts  from  resorting  to  judicial  action  (see  Section  8.3.1). 
Furthermore, as highlighted in Section 11.3, when a C2C dispute up to EUR 2,000 has a 
cross-border  nature,  the  European  Small  Claims  Procedure  could  be  invoked.  The 
availability  of  a  specific  small  claims  procedure  for  national  level  disputes,  depends  on 
the Member State (see Section 5.1 of the Task 5 Report).  

9.3  Practical application and current enforcement challenges  

This Section examines the enforcement of the existing national legal frameworks relevant 
to C2C transactions and online platforms facilitating P2P transactions and related issues 
and challenges encountered by national authorities.  

9.3.1  Challenges to enforcement of the national horizontal legislation applicable to C2C 

transactions 

The  national-level  analysis  shows  that  the  horizontal  legislation  applicable  to  C2C 
transactions may be scarcely or not enforced for various reasons (see also Section 5.1 of 
Task 5 Report). 

  Lack of competence of national consumer protection authorities: Several Member 
States156  underlined that national consumer protection authorities generally have 
limited  or  no  competence  at  all  over  C2C  transactions  and  can  only  enforce  B2C 
legislation.  

 

Issues  related  to  dispute  resolution  systems:  In  most  cases,  the  only  available 
mechanism  to  enforce  the  applicable  C2C  legislation  and  offer  redress  to  peer 
consumers  or  peer  providers  in  case  of  dispute,  consists  in  bringing  the  case  in 
front  of  civil  courts.  The  lack  of  reported  claims  brought  by  parties  to  C2C/P2P 
transactions  may  be  attributed  to  a  low  level  of  awareness  of  the  general  public 
about  the  available  remedies,  as  well  as  to  the  high  costs  and  length  of  civil 
proceedings  compared  to  the  average  low  value  of  C2C  transactions  concluded 
online.  Another  factor  which  may  prevent  people  from  bringing  disputes 
concerning online C2C transactions to courts may be the difficulty in obtaining the 

156 E.g. Austria (information collected through consultation with the Vienna Chamber of Labour on 23 May 2016, and 
the Austrian Chamber of Commerce on 24 May 2016);, Bulgaria (information collected through consultation with the 
Commission on Consumer Protection on 8 April 2016, and the Bulgarian National Association ‘Active Consumers’ on 10 
May 2016); Greece (information collected through consultation with the Consumer Ombudsman on 12 May 2016, and 
the Consumers’ Association ‘The Quality of Life’ on 13 May 2016);, Latvia (information collected through consultation 
with national stakeholder: Consumer Rights Protection Centre, 6 April 2016), Luxembourg (information collected 
through consultation with the Luxembourgish Union for Consumers on 28 April 2016, and the European Consumer 
Centre on 2 May 2016); Malta (website of the Consumers’ Association, http://www.camalta.org.mt/site/home.php); 
the Netherlands (information collected through consultation with the Netherlands Authority for Consumers and Markets 
on March 2016); Romania (website of the Association for Consumer Protection,  http://www.apc-romania.ro, and 
website of the Romanian Ombudsman, http://www.avp.ro); Slovakia (information collected through consultation with 
the Ministry of Finance consulted on 6 April 2016, and website of the Slovak Consumers Association, 
http://pravaspotrebitela.sk); Sweden (websites of the Swedish Consumer Agency, http://www.konsumentverket.se/, 
and website of the National Board of Consumer Complaints, http://www.arn.se/).  

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counterparty’s personal data from the platform. This is mainly due to the fact that 
most platforms set privacy standards under their general Terms and Conditions.157 
Finally,  the  generally  low  confidence  in  the  effectiveness  of  traditional  dispute 
resolution  tools  (i.e.  various  forms  of  civil  litigation)  seem  to  act  as  another 
deterrent for enforcement of rights derived from the general civil legislation.158  

 

In cross-border transactions litigation costs, translation duties and communication 
problems in cross-border disputes make it almost impossible for consumers to get 
effective legal remedies against foreign service providers/sellers.159 .  

  A  further  challenge  regarding  cross-border  transactions  may  be  the  differing 
contract  law  regimes  existing  in  the  different  jurisdictions  involved  in  these 
transactions.  National  contract  law  principles  differ  from  State  to  State  as  might 
expectations as to self-regulatory standards.160 

9.3.2  Challenges to  enforcement  of  the  national  sector-specific  legislation  applicable  to 

C2C transactions 

The  analysis  carried  out  at  national  level  identified  a  series  of  issues  enforcing  sector 
specific legislation (see also Section 5.2. of the Task 5 Report)  

The challenges regarding the enforcement of sector-specific legislation applicable to C2C 
transactions are outside the competence of national consumer protection authorities. and 
generally  relate  to  market  access  and  licensing  issues  which  are  outside  the  scope  of 
consumer policy. Where licensing requirements also apply to C2C transactions, they are 
not  necessarily  enforced  with  respect  to  private  individuals  providing  transport  or 
accommodation services on a non-professional basis by the sector-specific authorities.  

The  main  difficulties  in  enforcing  sector  specific  legislation  -  and  notably  provisions 
distinguishing  between  traders  and  private  peer  providers  -  relate  to  the  lack  of 
transparency  of  platforms’  rules  and  practices.  For  example,  where  platforms  are  not 
obliged to be equipped with the necessary technical tools to improve the information they 
provide  to  their  users,  the  enforceability  of  any  law  aimed  at  clarifying  the  distinction 
between  B2C  and  C2C  transactions  appears  difficult.  The  independent  website  Inside 
Airbnb161  highlighted  that  around  half  of  the  Amsterdam  flats  are  rented  out  through 
Airbnb  exceed  the  limit  of  60 days  per  year  set  out  by  the  Amsterdam  rules  on  private 

- 

- 

ReWear 

Markplaats 

(Storemates 

https://www.rewear.co/terms-and-conditions, 

https://img-ssl.vatera.hu/license/main.html?1012, 

-  https://storemates.co.uk/terms-conditions,  Liftshare 

157  E.g.  national  platforms:  UK 
- 
https://liftshare.com/uk/other/terms,  HiyaCar  -  https://hiyacar.co.uk/terms-and-conditions),  the  Netherlands  (Jipio  - 
http://www.jipio.nl/tos, 
- 
http://www.marktplaats.nl/i/help/over-marktplaats/voorwaarden-en-privacybeleid/algemene-
gebruiksvoorwaarden.dot.html),  Malta  (Second  hand  -  http://secondhand.com.mt/privacy-policy/),  Czech  Republic 
(Aukro  -http://aukro.cz/country_pages/56/0/user_agreement.php,  Půjčovna.cz  -  http://www.pujcovna.cz/obchodni-
podminky,  Sbazar.cz  -  https://napoveda.seznam.cz/soubory/Sbazar/Smluvni_podminky_Sbazar.cz.pdf),  Hungary 
(Vatera 
- 
http://www.oszkar.com/login/hazirend.php,  Bébiszitter  -  http://bebiszitter.info/aszf.php);  EU  platforms  (Airbnb  - 
https://www.airbnb.com/terms,  Wimdu  -  www.wimdu.co.uk/terms,  BlaBlacar  -  https://www.blablacar.co.uk/terms-
and-conditions,  Uber  -  https://www.uber.com/legal/terms/us/,  Easycar  -  https://carclub.easycar.com/,  Wallapop  - 
https://uk.wallapop.com/rules, 
- 
https://www.peerby.com/privacy, Yoopies - https://yoopies.fr/cgv/, Nimber - https://www.nimber.com/terms). 
158  Conclusions  provided  by  the  Hungarian  and  Czech  legal  experts.  Bulgaria  (information  collected  through 
consultation  with  the  Commission  on  Consumer  Protection  on  5  April  2016);  Finland  (information  collected  through 
consultation with the Consumer Union on 18 May 2016).  
159  Information  collected  through  consultation  with  the  Hungarian  Association  of  Consumer  Protectors  on  14 
April 2016. 
160  E.g.  Spain  (information  collected  through  consultation  with  national  stakeholders:  Catalonian  Competition 
Authority,  26  May  2016;  Ouishare,  2  June  2016;  Consumers’  and  Users’  Organisation,  2  June  2016; 
Representative  of  the  Government,  13  June  2016;  Catalonian  Government,  General  Directorate  for 
Telecommunications and Information Society, 15 June 2016). 
161 Inside Airbnb website available at 
http://insideairbnb.com/amsterdam/index.html?neighbourhood=&filterEntireHomes=false&filterHighlyAvailable=false&
filterRecentReviews=false&filterMultiListings=false. 

-  http://pages.ebay.com/help/policies/user-agreement.html, 

Telekocsi 

Oszkár 

Peerby 

eBay 

 
 
 
 
 
                                                 
 
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holiday  rentals.162  Furthermore,  by  checking  the  calendars  set  by  peer  suppliers 
operating  in  Amsterdam  for  their  listing,  Inside  Airbnb  found  that  the  51,6  %  of  entire 
homes and apartments rented out through the platform result highly available during the 
whole  year,  and  24,6  %  of  peer  suppliers  have  multiple  listings.163    This  highlights  the 
difficulty in using sector-specific thresholds to distinguish between professional and non-
professional  activities  without  the  voluntary  cooperation  of  online  P2P  platforms,  or 
without rules specifically imposing transparency requirements on these platforms.  

Enforcement issues might also arise from the fact that most online P2P platforms do not 
enable their users to clearly state whether they are acting as traders.  

Information  collected  through  the  Country  Reports  also  shows  that  online  platforms 
usually  do  not  set  out  strict  verification  systems  of  users’  identity.  Consequently, 
enforcement issues could arise from the way the platforms’ users behave. For example, 
some  users  might  provide  false  information  or  create  fake  accounts,  a  practice  that 
makes  their  detection  by  authorities  extremely  difficult.  The  Greek  Consumer 
Ombudsman164  emphasised 
intersection, 
the  great  difficulties  of 
identification  and  banning  of  those  users  that  violate  the  platform’s  general  Terms  and 
Conditions.  

investigation, 

Finally, platforms tend to argue that they do not qualify under the definitions of national 
sector-specific provisions applying to the accommodation and transport service providers 
and,  thus,  do  not  need  to  fulfil  the  requirements  laid  out  therein,  mostly  regarding 
licensing  and  taxes.165    Enforcement  of  sector  specific  legislation  to  P2P  platforms  will 
therefore in many cases depend on court decisions determining if platforms fall within the 
definitions  set  out  by  sector-specific  legislation  and,  thus,  should  comply  with  their 
corresponding legal requirements. 

162 ‘May I let my home or home boat when I am on holidays?’ (Mag ik mijn woning of woonboot verhuren als ik op 
vakantie ben?), website of the Municipality of Amsterdam, available at 
https://www.amsterdam.nl/veelgevraagd/?caseid=%7B9B2C2273-F797-460B-AD20-05DFB9F6F39F%7D. 
163 Ibid. 
164 Information collected through consultation of the Greek Consumer Ombudsman on 12 May 2016. 
165 E.g.: multi-country platforms (Wimdu, Wallapop, Airbnb, Uber); national platforms: Denmark (GoMore), Estonia 
(Taxify), Italy (Homeaway), Malta (Second Hand), Portugal (Oxl), Spain (Socialcar). 

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10 Potential future market developments in online P2P platform 

markets  

The survey results in this study have shown that more than three quarters of P2P users 
are satisfied or very satisfied with P2P platforms and another 17,3% of the respondents 
have not used any of the platforms but are likely to use them in the future. It is therefore 
likely that use of P2P platform services will further increase in the future. In particular, in 
the  collaborative  sectors  there  is  significant  potential  for  growth.  Such  growth  can  only 
be  accommodated  by  wider  societal  penetration,  which  depends  on  whether  consumer 
groups  which  currently  do  not  participate  in  certain  online  P2P  markets  will  decide  that 
such platforms are  reliable,  safe  and  offer  good value  for money.  This  means  platforms 
may  want  to  review  their  self-regulatory  practices.  It  also,  in  turn,  indicates  the 
importance  for  regulators  to  understand  the  way  in  which  P2P  markets  work,  the  risks 
and rewards that they offer peer consumers and providers and platforms, and how online 
P2P  platform  business  models  relate  to  the  current  regulatory  framework  in  the  field  of 
consumer and marketing law.  

Already,  the  increased  attention  and  involvement  of  policy-makers  is  leading  to 
regulatory  developments  at  Member  State  level.  As  Section  8  has  shown,  several 
countries  have  already  engaged  in  efforts  to  regulate  the  sharing  or  collaborative 
economy  and/or  P2P  markets,  including  initiatives  in  France166,  Italy167,  Belgium168, 
Germany169, Croatia170, the UK171 or Spain172. Furthermore, aside from the present study 
which  focuses  on  consumer  policy  issues,  several  EU  level  initiatives  and  studies  are 
underway  to  analyse  the  phenomenon  of  P2P  markets  and  online  platforms  in  greater 
detail and to devise appropriate policy responses. 

As  part  of  this  study,  the  two  workshop  discussions,  together  with  subsequent 
stakeholder inputs, provided useful indications of potential future developments that may 
inform future regulatory interventions regarding consumer and other policy issues at EU 
and national levels. 

First  of  all,  in  the  future,  P2P  platforms  could  have  easier  access  to  data  for  checking 
user ID information or service demand. The UK (ranked173 number 1 in 2013 on the open 
data  barometer)  is  a  good  example  of  public  data  transparency.  The  UK’s  Open  Data 
Roadmap,174 launched in December 2014, aims to make data transparent, from both the 
public  and  private  sector  alike.  In  March  2015,  2,000  datasets  were  released175  by  the 
government  on  data.gov.uk,  on  topics  ranging  from  environment  to  public  spending.176 
As outlined in section 7, the UK Government Digital Service also intends to open-up the 
public identity verification scheme to private stakeholders, including P2P platforms.177 

While  open  data  is  meant  to  encourage  innovation,  novel  uses  of  information  and 
increased  transparency  for  consumers,  some  researchers  also  point  out  potential 

166 The Digital Republic bill in France, available at: https://www.senat.fr/leg/pjl15-744.html  
167 A draft bill for regulating the sharing economy in Italy is available at: 
http://www.camera.it/leg17/126?tab=2&leg=17&idDocumento=3564&sede=&tipo=  
168 A Belgian law from July 1st discusses the taxation of sharing economy revenues. The text is available at: 
http://www.ejustice.just.fgov.be/mopdf/2016/07/04_2.pdf#Page2  
169 The German Ministry for Economic Affairs and Energy launched a consultation on digital platforms. The text is 
available at: http://www.bmwi.de/English/Redaktion/Pdf/green-paper-digital-
platforms,property=pdf,bereich=bmwi2012,sprache=en,rwb=true.pdf  
170 A sharing economy working group was organised by the Ministry of the Economy in Croatia.  
171 https://techvibes.com/2016/12/05/how-regulations-are-turning-the-sharing-economy-into-the-regular-economy 
172 The Catalan government recently created an inter-service working group on the sharing economy. 
173 http://www.opendataresearch.org/dl/odb2013/Open-Data-Barometer-2013-Global-Report.pdf  
174 http://theodi.org/news/the-odis-open-data-roadmap-for-the-uk-is-launched  
175 https://data.blog.gov.uk/2015/03/24/progress-on-the-national-information-infrastructure-project/  
176 The newly-created National Information Infrastructure aims to improve the quality, interoperability (e.g. to be used 
for apps as well as desktop software) and spread of such data.  
177 https://www.gov.uk/government/publications/introducing-govuk-verify/introducing-govuk-verify 

 
 
 
 
 
                                                 
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drawbacks.  Indeed,  knowledge-extraction  algorithms  and  large-scale  machine  learning 
could  lead  to  larger  firms,  less  bottom-up  innovation  (i.e.  innovation  driven  by  small 
firms) and more job destruction through digitalisation.178 

Second,  during  the  first  workshop,  stakeholders  suggested  that  larger  platforms  will  be 
more  likely  to  host  both  P2P  and  B2C  exchanges  (  “hybridisation  of  platforms”).  B2C 
firms are increasingly common on (Re)Sale platforms such as eBay or GumTree, but also 
on  collaborative  platforms  such  as  AirBnB  or  Freelancer.com.  Along  these  lines,  large 
platforms  may  evolve  to  host  an  increased  number  of  “P2B2P”  transactions  (i.e.  P2P 
transactions  with  a  third-party  business  intermediary  making  the  link  between  the  two 
peers and dealing directly with the platform). 

Third, workshop participants suggested that large platforms which currently do not play a 
significant  role  in  P2P  markets  are  likely  to  enter  this  market  (e.g.  Google,  Amazon, 
Facebook, etc.). For instance, Facebook has recently introduced options to facilitate P2P 
transactions  on  the  platform  through  “buy  and  sell  groups”.179  Google’s  Google  Plus 
communities  also  allow  P2P  transactions  through  posting  classifieds.180  Both  initiatives 
allow  both  peers  and  professionals  to  use  their  services.  The  entry  of  these  very  large 
companies  into  P2P  markets  is  likely  to  considerably  extend  the  reach  of  P2P 
transactions,  cover  additional  sectors,  and  offer  additional  services  beyond  P2P 
transactions  and  introduce  significant  competition  for  user  growth  for  incumbent 
platforms in these markets.  

The  main  P2P  players  already  prepare  for  these  market  changing  conditions.  For 
instance,  Uber’s  new  app  combines  peer  to  peer  rides  with  trains  or  bus  timetables  to 
e.g. reduce layovers and provide a more comprehensive mobility service.181 New lifestyle 
features  allow  peers  to  personalise  the  user  experience,  using  tools  such  as  calendars, 
weather and news information, and restaurant reviews.182 It is likely that over time Uber 
will develop into a broader service which uses the significant amount of user data that it 
collects  to  offer  a wide  range  of  services  going  well  beyond  ride-sharing.  Similar  trends 
can  be  also  observed  on  AirBnb  with  its  recent  shift  towards  one-stop-shop  solution  for 
all travel needs. It will be important to monitor the extent to which these platforms’ data 
use and re-use policies reflect the development of their business models. 

Fourth,  the  “uberisation”  of  the  economy  refers  to  the  shift  to  platform-based  models, 
where consumers and providers exchange services with a very low transaction cost.183 In 
such environments, as this study and others have shown, a small group of platforms may 
be  able  to  capture  a  disproportionate  share  of  economic  activity,  and  to  acquire  large 
datasets that facilitate their control over markets.  This presents a future risk of  a small 
group of platforms exercising significant influence over specific sectors. One potential risk 
would  be  that  platforms  might  take  advantage  of  their  influence  as  intermediaries  to 
impose restrictive rules or prices on peers.184;185;186  

Given  that  an  increasing  number  of  peer  providers  are  likely  to  become  dependent  on 
P2P  platforms for their income,  this  might  lead  to  less  job  security  and  limits  on  career 
advancement187  (see  also  the  current  controversy  over  employment  rights  on  Uber, 
Deliveroo and other platforms).188 Since – according to the platforms - peer providers act 

178 http://brie.berkeley.edu/brie/publications/huberty_etla_big_data.pdf  
179 https://www.facebook.com/help/1557451221155310  
180 https://plus.google.com/communities/106516375376950044317  
181 http://venturebeat.com/2016/11/02/uber-is-rolling-out-a-big-redesign-powered-by-machine-learning/ 
182 https://www.ft.com/content/e7113970-a06b-11e6-891e-abe238dee8e2 
183 http://www.brie.berkeley.edu/wp-content/uploads/2015/02/Kenney-Zysman-The-Rise-of-the-Platform-Economy-
Spring-2016-ISTx.pdf  
184 http://www.spiegel.de/netzwelt/netzpolitik/sascha-lobo-sharing-economy-wie-bei-uber-ist-plattform-kapitalismus-
a-989584.html  
185 https://medium.com/@trebors/platform-cooperativism-vs-the-sharing-economy-2ea737f1b5ad#.7uuhp8mpm  
186 http://www.spiegel.de/wirtschaft/soziales/uber-und-airbnb-ethik-der-share-economy-a-988612.html  
187 http://www.iftf.org/fileadmin/user_upload/downloads/wfi/IFTF_WFI_Voices_of_Workable_Futures_2016.pdf  
188 http://www.brie.berkeley.edu/wp-content/uploads/2015/02/Innovative-Clusters-New-Work.pdf  

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in their own capacity rather than through a company, it becomes more difficult for them 
to collectively protect their interests.189  

It has also been argued that, in such an environment, start-ups will increasingly produce 
innovation  to  feed  into  existing  platforms,  rather  than  create  standalone  products,  and 
that – as a result - digitalisation could replace the role of peer providers (e.g. driverless 
cars  could  replace  Uber  drivers)  in  some  sectors.  Policymakers  will  need  to  take  these 
developments  into  account  in  striving  for  a  balance  between  flexibility  and  social 
protection for peers190. 

Finally,  counterbalancing  some  of  the  above developments  which  favour  the  emergence 
of  a  small  number  of  very  powerful  platforms,  blockchain  technology  could  become 
pervasive across P2P markets, eliminate the need for a platform intermediary191 (the so-
called  “sharing  economy  2.0”)  and  fundamentally  disrupt  current  business  models. 
Blockchain  could  allow  individuals  to  interact  and  transact  directly  with  each  other, 
without  relying  on  a  platform’s  matching  algorithms.  Combined  with  a  crypto-currency, 
blockchain  could  enable  peers  to  transact  in  tokens  and  monetise  many  activities  that 
cannot  be  monetised  at  present.  One  version  of  blockchain-based  P2P  platform  is 
Arcade.City192,  a  platform  connecting  drivers  to  customers  in  a  decentralised  way,  and 
which uses Bitcoin as legal tender. 

189 http://www.irle.berkeley.edu/workingpapers/114-15.pdf  
190 http://www.brie.berkeley.edu/wp-content/uploads/2015/02/PlatformEconomy2DistributeJune21.pdf  
191 http://www.ibm.com/developerworks/library/iot-blockchain-sharing-economy/index.html  
192 https://arcade.city/  

 
 
 
 
 
 
 
                                                 
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11 Overview of key conclusions 

KEY FINDINGS AND CONCLUSIONS 

A.  Economic analysis of P2P markets 

Economic significance of P2P transactions 

It is estimated that 191m citizens across the EU-28 have actively engaged in peer to peer 
markets between May 2015 and May 2016, concluding at least one transaction involving 
payment. 

Total  peer  expenditure  over  this  period  in  the  EU  across  the  five  sectors  considered  in 
this study is estimated at EUR 27.9 billion per year; total peer revenues are estimated at 
EUR  17.29  billion.  The  difference  of  EUR  10.61  billion  includes  platform  revenues  and 
revenues  of  third  parties  providing  services  via  platforms,  e.g.  payment  services, 
background and ID checks, insurance services. 

The  difference  between  the  estimated  peer  consumer  expenditure  and  peer  providers 
revenue is significantly lower in ride sharing/hiring than in the other P2P markets: in the 
sharing/hiring rides sector 81% of estimated expenditure reaches peer providers; in the 
(re)sale  or  renting/sharing  of  goods,  accommodation  sharing/renting  and  odd  jobs 
sectors,  only  about  60  to  65%  of  total  peer  expenditure  reaches  peer  providers.  The 
reason for such differences could include e.g. delivery costs in the (re)sale and sharing of 
goods  sector,  tourist  taxes  or  cleaning  costs  in  the  accommodation  sector,  or 
underreporting by peer providers. 

Estimated peer spending is highest on (re)sale of goods platforms (EUR 17.8 billion), and 
amongst  the  collaborative  platforms  on  sharing/renting  accommodation  platforms  (EUR 
6.6 billion). Estimated peer revenues on (re)sale of goods platform are estimated at EUR 
10.8 billion; on sharing/renting accommodation revenues add up to EUR 4.1 billion, and 
in each of the other three sectors at around EUR 800 million per year. 

Expenditure and revenue on both collaborative and (re)sale of goods platforms are driven 
by  a  small  share  of  peer  consumers  and  peer  providers.  More  than  half  of  the  revenue 
and  expenditure  is  generated  by  10%  of  peers.  This  skewed  distribution  of  expenditure 
and  revenue  indicates  the  presence  of  'very  active  private'  consumers  and  providers, 
and/or  of  commercial  and  professional  buyers  and  sellers  transacting  frequently  in  P2P 
markets.  

Among the 485 platforms screened for this study there are large differences in platform 
size  insofar  as can  be deducted from  unique visitor numbers  of websites.  both between 
the  P2P  markets  and  within  them.  A  large  majority  of  the  platforms,  81%  of  the  485 
platforms  in  the  sample,  are  small  or  medium-sized  (below  10,000  daily  visitors)  while 
20 platforms or 4% of them, are very large and have more than 100.000 unique visitors 
per  day.  Depending  on  the  sector,  21  to  41%  of  platforms  examined  operate  an  app, 
either  exclusively  or  in  addition  to  a  website  –  no  data  for  app  use  were  available.  The 
websites  of  (re)sale  platforms  are  by  far  the  most  visited  and  it  is  in  this  sector  where 
there  are  the  largest  differences  in  platform  size  or  popularity.  The  overwhelming 
majority  of  sharing/hiring  rides  or  odd  jobs  platforms  (78%  and  68%  of  platforms 
respectively) are small (defined as <500 daily unique visitors). 

Finally,  there  are  serious  and  large  gaps  in  the  availability  of  data  about  the  economic 
activity  of  platforms,  such  as  financial  records,  and  a  lack  of  transparency  and  data 
availability about platform activity in general.  

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Online P2P platform business models   

The screening of 485 platforms shows that peer to peer online platforms provide a wide 
range of services to peers which go well beyond the mere hosting or matching of demand 
and supply. These include:  

  Pre-transaction  services  such  as  search  and  matching  tools,  provision  of  tax  and 
safety  information,  marketing  services,  user  data  checks and  identity  verification 
services, and peer review and rating systems;  

  Transaction  services  such  as  price  setting  services,  payment  services,  setting 
terms and conditions for platform use and for the transaction between peers (e.g. 
regarding cancellations or refunds); 

  Post-transaction  services  such  as  complaints  handling,  management  of  refunds, 
insurance,  compliance  monitoring,  monitoring  of  user  activity,  invoicing  and  tax 
declaration services 

The services P2P platforms provide differ between platforms, depending among others on 
the  (value  of)  the  good  or  service  to  be  exchanged,  the  country  or  the  level  of 
development of the platform. But a very large majority (86%) set terms and conditions 
for using the platform.  

About 60% of the peer to peer platforms analysed engage actively in matching demand 
and supply through algorithms, search functions, geolocation and other tools, as opposed 
to  simply  hosting  listings  posted  by  peers.  To  build  trust,  about  50%  manage  a  peer 
review  or  rating  system,  48%  give  safety  advice  and  rules  and  25%  have  systems  for 
user data checks or identity verification.  

At  the  transaction  phase  55%  offer  payment  services  that  are  accessed  through  the 
platform.  About  a  third  (35%)  set  terms  and  conditions  for  peer  to  peer  transactions. 
More  than  one  in  five  (22%)  platforms  either  offers  pricing  guidance  or  price  setting 
services for the peer transaction. 

At  the  post  transaction  phase  53%  engage  in  complaint  handling.  Around  30%  monitor 
user  activity  and  27%  monitor  compliance  with  platform  and  other  rules.  About  one  in 
four platforms offer insurance coverage and handle insurance claims, either as part of the 
transaction or as an optional add-on service.   

The literature review identified the following monetisation models of online platforms: 

  Transaction fees: fees charged on transactions intermediated by the P2P platform, 

to peer consumers and/or peer providers; 

  Subscription fees: fees charged on a periodical basis by the platform to peers for 

access to its services; 

  Add-on  services  fees:  fees  charged  for  optional  add-on  services  by  the  platform 
outside  the  transaction  or  on  top  of  the  transaction  fees  ,  such  as  promoted 
listings,  professional  photographs,  verification  of  identity,    delivery,  insurance, 
etc.; 

  Advertising:  revenue  generated  through  advertising  third-party  content  on  the 

platform through banners, native advertising, etc.; 

  Data  use/reuse:  revenue  generated  through  sharing  or  selling  peer  data  to  third 

parties193; 

193 Note that this study considers a platform uses data as a revenue source if its Terms and Conditions specify that it is 
allowed to share peer data with third parties for, among others, marketing purposes. It is not clear which platforms 

 
 
 
 
 
                                                 
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  Other: other revenue generation such as cancellation fees, consumer hotline fees, 

B2B services, etc. 

The  screening  of  485  platforms  also  shows  that  advertising  is  the  most  prevalent 
monetisation  model,  used  by  53%  of  platforms;  48%  use  and  reuse  data  to  generate 
income,  a  third  of  platforms  (34%)  use  transaction  fees,  21%  subscription  fees,  and  
12%  add-on  services  fees.  A  majority  of  platforms  use  a  combination  of  strategies  to 
generate  revenue.  Over  half  of  the  platforms  use  advertising  in  combination  with 
subscription  fees  (51%),  add-on  service  fees  (61%)  or  data  use/reuse  (64%).  Data 
use/reuse is also usually combined with a second monetisation model.  

Between P2P sectors, there are differences in the prevalence of monetisation strategies: 
Most  (re)sale  of  goods  platforms  (80%)  use  advertising  or  data  use/reuse  (60%)  as  a 
monetisation strategy. The sharing/hiring rides market features the greatest diversity of 
monetisation models. 

By  linking  the  types  of  services  with  the  different  monetisation  models,  three  ways  in 
which peer to peer platforms create value that can be monetised can be identified:   

  Transaction/subscription-fee  based  models:  such  platforms  offer  a  wide  range  of 
services  with  a  focus  on  pre-transaction  services.  Their  aim  is  to  encourage  a 
maximum  number  of  transactions  by  offering  a  wide  range  of  well  diversified 
services, in function of their level of maturity and financial solidity. 

  Advertising-based models: their activity focuses more on post-transaction services 
and  less  on  trust-building.  They  tend  to  adopt  more  reactive,  rather  than 
proactive approaches to potential user issues and problems. 

  Data  use  and  re-use:  platforms  using  this  model  offer  a  wide  range  of  services 
and  they  often  combine  this  model  with  either  advertising,  transaction  fees  or 
subscriptions fees. 

Combing these findings on combinations of monetisation strategies and platform services 
with  the  findings  of  the  case  studies,  three  main  platform  business  models  can  be 
distinguished:  

Model 1. Hosting of Listings 

The  first  model  concerns  platforms  which  limit  themselves  to  passively  matching  peer 
demand  and  peer  supply  by  publishing  information  about  the  relevant  peer  to  peer 
market,  with  or  without  user  generated  reviews  of  the  peers  or  of  the  good/service 
alongside  the  listing.  Most  such platforms offer  a search  function  based  on  keywords  to 
facilitate the matching.  

These platforms do not get involved in the peer to peer transaction, but limit themselves 
to providing a matching service. They tend to monetise the value they create by charging 
for advertising, charging fees for add-on services such as premium listings, and through 
data reuse, monetising user data shared with the platform. 

actually gain monetary value from peer data, but this study considers that all platforms which enable themselves to 
use peer data in this way in their Terms and Conditions end up doing so. 

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Model 2. Active management of transactions  

The  second  model  is  characterised  by  platform  services  that  create  value  by  actively 
facilitating and managing the matching of demand and supply and fostering trust among 
peers to facilitate a larger number of transactions.  

The  services  these  platforms  offer  include  advanced  search  tools  and  messaging 
systems;  user  information  checks,  pre-screening  or  verification  of  identity  documents; 
pricing  guidance;  guidance  for  safe  P2P  interactions;  management  of  peer  review  and 
reputation systems.  

Platforms  tend  to  monetise  the  value  they  create  in  this  type  of  transaction  through 
charging  subscription  or  transaction  fees  and  through  data  reuse.  Most  platforms  that 
actively manage P2P transactions charge transaction fees; they may also charge for add-
on services like insurance, or featured listings.  

Platforms with this business model influence the peer to peer transaction but they do not 
control the contractual terms of the P2P transaction.  

Model 3. Platform governed peer transactions 

The  third  model  is  characterised  by  platforms  services  setting  one  or  more  contractual 
terms  for  the  peer  to  peer  transaction,  and  exercising  control  over  the  performance  of 
the  transaction,  assuming  explicitly  or  implicitly  (partial)  responsibility  for  the 
performance or quality of the transaction.  

Platforms that set terms and conditions and control P2P transactions provide price setting 
services;  management  of  payments,  holding  payments  until  performance  of  the  service 
or  arrival  of  the  good  is  confirmed;  management  of  complaints  and  refunds;  and 
insurance as part of the transaction fee. Platforms tend to monetise the value they create 
in  this  type  of  transaction  through  transaction  fees  and  through  data  reuse.  Most 
platforms in this category charge transaction fees.  

Such platforms govern key terms of the contract between the peers and they assume  a 
level of responsibility for its successful completion. This may raise legitimate expectations 
among  users  regarding  the  reliability  and  quality  of  the  transaction  and  the  platform’s 
responsibility in case of problems.  

Platform  control  over  the  P2P  transaction  is  at  the  core  of  these  business  models.  
Greater  control  over  the  transaction  implies  greater  platform  responsibility  for  the 
performance  and  quality  of  the  transaction.  At  any  one  point  in  time,  a  single  platform 
can  operate  several  of  these  business  models  at  once,  e.g.  for  different  consumer 
segments, for different types of goods or services, or with different types of providers. In 
practice, the third model is limited to larger platforms which have both the need and the 
resources to actively manage matching and govern peer to peer contracts.  

Finally,  as  platforms  develop  a  larger  user  base,  there  is  an  evolution  of  platform 
business models over time from the simpler (listings) model to the more complex models 
of  active  management  and  governing  the  terms  of  the  peer  to  peer  transaction,  and 
offering a wider array of services to its users. 

 
 
 
 
 
 
 
 
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B.  Peer experiences in online P2P markets 

Peer usage of online P2P platforms  

More  than  three  quarters  of  internet  users  in  the  ten  countries  surveyed  for  this  study 
has  over  the  past  12  months  used  a  peer-to-peer  (P2P)  online  platform  to  conclude 
transactions with other peers. Most of them (73%) had experience with online platforms 
for the Sale and Resale of Goods which have existed since the 1990's. Engagement with 
collaborative  platforms  which  are  a  more  recent  phenomenon  ranges  from  8%  using 
for  Sharing/Renting  of  Goods,  14% 
platforms 
Accommodation  Renting/Sharing  to  15%  of  the  online  population  using  Ride 
Sharing/Hiring  platforms.  A  large  majority  of  platform  users  were  both  active  as  peer 
consumers and as peer providers, and this is the case across all P2P sectors. 

for  Odd  Jobs,  12%  platforms 

About half of both peer providers (54%) and peer consumers (44%) who use these P2P 
platforms do so with either a monthly or weekly frequency. A substantial portion of peer 
providers in the accommodation sector report they rent out accommodation on a regular 
basis,  15.9%  once  a  week  and  20.6  %  once  a  month,  but  peer  consumers  use  such 
platforms less frequently, mostly once or twice a year.  

Most peer users are either satisfied or very satisfied and want to use the platform again 
in the future. Altogether, peer consumers are slightly more satisfied than peer providers: 
77%  of  peer  providers  are  satisfied  or  very  satisfied  compared  to  83%  of  peer 
consumers. 

Problems experienced  

Notwithstanding  their  overall  satisfaction  with  P2P  platforms,  peer  consumers  in  the  10 
countries  surveyed  report  frequent  problems  with  transactions  on  P2P  platforms.  More 
than  half  (55%)  has  experienced  at  least  one  problem  over  the  past  year.  The  most 
frequent  problems  relate  to  the  poor  quality  of  goods  or  services,  or  to  the  goods  and 
services not being as described.  

About  a  quarter  of  these  peer  consumers  report  they  had  similar  problems  with 
conventional  businesses,  but  a  large  majority  say  they  only  had  such  problems  on  P2P 
platforms. Problems with the quality of the product or service appear to be almost twice 
as frequent in P2P markets (29%) as in online purchases in general (15%) 194.  

Peer  consumers  rated  the  personal  detriment  they  experienced  as  a  result  of  these 
problems on P2P platforms as low to medium. The average level of detriment as a result 
of  problems  experienced  by  peer  consumers  on  P2P  platforms  -  insofar  as  valid 
comparisons  can  be  made  -  is  lower  compared  to  similar  types  of  services  in  the 
traditional  economy.  This  is  likely  to  be  related  to  the  fact  that  the  sums  involved  on 
online  P2P  platforms  are  generally  lower.  The  focus  group  research  conducted  for  this 
study in the same 10 countries indicates that peer consumers may accept a higher level 
of  risk  and  problems  on  P2P  platforms  as  "part  of  the  game"    -  in  exchange  for  the 
opportunity to save money, and because most transactions are relatively low value. 

Across  different  platform  types,  peer  consumers  experienced  more  problems  on 
collaborative  platforms  than  on  (Re)Sale  of  goods  platforms.  Those  who  experienced 
problems on resale platforms also report a lower level of detriment than on collaborative 
platforms.  But  full  refunds  were  more  frequently  obtained  on  resale  platforms  than  on 
collaborative  platforms.  Problems  on  accommodation  platforms  were  less  likely  to  get 
resolved than problems on other collaborative platforms. 

194 Comparing the current findings for 10 countries with the results of the Digital Single Market Study for 28 EU 
: 
Member 
http://ec.europa.eu/consumers/consumer_evidence/market_studies/obstacles_dsm/docs/21.09_dsm_final_rep
ort.pdf 

States 

2015 

in 

116 

 
 
                                                 
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Peer providers  report  fewer  problems  (14%)  with  the  other  peer  on  P2P  platforms than 
peer  consumers.  Most  of  these  problems  of  peer  providers  relate  to  cancellations  (over 
40%)  and  various  payment  issues  (47,5%).  On  average,  providers  experience  less 
problems  on  (Re)Sale  platforms  (13%)  and  Sharing/Hiring  Rides  platforms  (11%)  than 
on accommodation or sharing/renting of goods platforms (16%). The highest incidence of 
provider problems is reported on Odd Jobs platforms (22%)   

Actions taken by peer to solve problems 

Almost  half  of  the  peer  consumers  (46%)  that  had  experienced  a  problem  did  not  take 
any action, mostly because they felt it was not worth their time or effort and/or because 
the  amount  of  money  involved  was  too  small.  When  peer  consumers  took  action,  they 
mostly  complained  to  the  peer  provider  or  to  the  platform.  Remarkably  few  peer 
consumers (20.4%) left a low rating or bad review.  

In contrast, peer providers were more likely to take action when experiencing a problem: 
71% of them took action, by complaining directly to the peer consumer (36%) or to the 
platform (34%), or to a consumer association or authority (8%); 23% resorted to giving 
a low ranking or bad review of the other peer. Of those who complained to the platform, 
about half were satisfied with how the platform responded.  

The  findings  also  show  that  taking  action  helped  solve  peer  consumer  problems.  More 
than 60% of peer consumers who took action with the other peer succeeded in solving all 
or most of their problems; about 45% of those who complained to the platform had all or 
most of their problems solved, and 45% of those who appealed to the payment provider 
were  successful  in  getting  their  money  back.  Most  peer  consumers  obtained  a  full  or 
partial refund, or another form of financial compensation, from the peer  provider or the 
platform.  Peer  consumers  who  reacted  to  problems  by  giving  bad  ratings  or  reviews 
mostly did not get their problems solved. 

Peer knowledge of rights and responsibilities 

Given  the  relatively  high  incidence  of  problems  on  P2P  platforms,  peers’  knowledge  of 
their rights and responsibilities on P2P platforms and the importance they attribute to the 
transparency and clarity of the information given by the platform about this are relevant. 
The  (self-reported)  knowledge  of  the  rights  and  responsibilities  is  overall  rather  low: 
about  60%  of  peer  consumers  do  not  know  or  are  not  sure  who  is  responsible  when 
something goes wrong, what the responsibility of the platform is or if they have a right to 
compensation or reimbursement. About 40% of peer providers say they do not know or 
are not sure about their rights and responsibilities, and about 30% think they know more 
or less.  

At the same time, about 85% of peer consumers find it important or very important that 
P2P platforms are clear and transparent about who is responsible when something goes 
wrong, data protection and their rights in case of a problem with the price or quality of a 
product  or  service.  Peer  providers  attach  similar  importance  to  clarity  and  transparency 
about  the  regulations  and  responsibilities  when  something  goes  wrong,  data  protection 
and tax responsibilities. The apparent lack of knowledge or uncertainty about rights and 
responsibilities  and 
rights  and 
responsibilities indicate a need for clearer information about this. 

transparency  about 

importance  given 

the 

to 

 
 
 
 
 
 
 
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C.  Clarity and transparency of information on P2P platforms 

The  case  study  platforms  analysis  shows  diverging  practices  in  transparency  about 
platform  functioning  towards  peers.  All  case  study  platforms  qualify  as  ‘traders’  and 
engage  in  B2C  commercial  activities.  As  such  they  are  subject  to  the  professional 
diligence  duty  set  out  by  Article  5(2)  of  the  UCPD  and  the  transparency  requirements 
included  in  Articles  6(1)(b)  and  7(4)(a)  of  the  UCPD.  The  European  Commission’s 
Guidance  on  the  Implementation/Application  of  the  UCPD  (UCPD  Guidance),195  clarifies 
that in order to comply with such duties, platforms should adopt a series of appropriate 
measures aimed at clarifying to their users with whom they are concluding contracts on 
the  platform  itself.  Additionally,  platforms’  liability  should  also  extend  to  adequately 
ensuring their users’ identity. According to the UCPD Guidance, indeed, platforms should 
adopt  any  necessary  ‘technical  means  to  verify  the  reliability  of  the  person  posting  a 
review, for instance by requesting him/her to register’.196 

With regard to these requirements, the research finds the following: 

Contractual nature of the transaction and liability:  

Some platforms do not allow or make it difficult for commercial peer providers to operate 
alongside  private  peers;  others  allow  both  types  of  peers  and  require  peer  providers  to 
indicate  their  legal  status.  But  some  of  the  major  platforms  do  not  distinguish  between 
private and professional providers, although it is technically feasible to be transparent. 

This  lack  of  clarity  and  transparency  regarding  the  peer  provider’s  status  is  a  major 
concern because the peer provider’s status determines the applicability of consumer and 
marketing  legislation.  It  may  not  generate  any  substantial  problems  in  the  case  of 
platforms serving smaller local communities, and/or where transaction amounts are low. 
But  on  larger  platforms  which  give  peers  opportunities  to  make  significant  profit,  not 
identifying  peers  who  are  acting  as  professionals  or  traders,  implies  they  may  act  as 
'hidden traders' which is not acceptable from a consumer policy perspective. 

Platform liability for the P2P transaction  

Insofar as case study platforms explain the role and responsibility of the platform, this is 
mainly  to  exclude  responsibility  or  liability.  There  is  no  clear  information  about  the 
applicability  of  consumer  or  contractual  rights,  or  who  is  responsible  if  something  goes 
wrong. However, there are on most platforms extensive FAQ sections explaining to peers 
what to do in case of problems, which creates the impression the platform does assume 
responsibility and will provide assistance in case of problems. 

In  particular,  there  is  a  discrepancy  between  platform  practices  and  their  terms  and 
conditions  regarding  liability  or  responsibility  for  the  P2P  transaction.  Most  case  study 
platforms  set  at  least  part  of  the  contractual  terms  of  the  P2P  transaction.  This  may 
create  the  impression  among  users  that  the  platform  shares  a  certain  degree  of 
responsibility in case of non-performance or non-compliance of the performance.  

Such impressions can for instance be created by:  

  holding  payments  until  performance/compliance  of  the  service  is  confirmed  or 
withholding payment in case of non-performance or non-compliance by peers. 

 

 

 

imposing rules and fees for cancelations by peer consumers or peer provider.  

intervening to solve problems between peers through management of complaints, 
mediation of disputes and award of refunds. 

intervening  to  enhance  safety  and  security  by  verification  of  peer  identities,  or 
creating the impression that identities are verified. 

195  Commission  Staff  Working  Document  Guidance  on  the  Implementation/Application  of  Directive  2005/29/EC  on  Unfair 
Commercial  Practices,  accompanying  the  document  Communication  from  the  Commission  to  the  European  Parliament,  the 
Council,  the  European  Economic  and  Social  Committee  and  the  Committee  of  the  Regions  ‘A  comprehensive  approach  to 
stimulating  cross-border  e-Commerce  for  Europe's  citizens  and  businesses’,  UCPD  Guidance,  25.5.2016,  COM  (2016)  320,  p. 
123. 
196 UCPD Guidance, 25.5.2016, COM (2016) 320, supra, p. 137. 

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 

(optional)  automatic  price-setting  based  on  algorithms  using  internal/external 
demand/supply data. 

At the same time, the terms and conditions of these platforms systematically exclude any 
liability  of  the  platform  in  relation  to  the  contracts  concluded  between  the  peers,  and 
explicitly  state  that  the  platform  is  not  a  party  to  such  contracts.  For  instance,  all  case 
study platforms exclude liability for: 

 

the accuracy of information provided by the peer to establish whether they are a 
commercial or a private provider; 

  non-performance, non-compliance of the performance by the peer providers; 

 

the accuracy of information provided in peer-to-peer reviews. 

The discrepancy between the platforms' level  of intervention in  setting the terms of the 
P2P transaction and the liability clauses in its T&Cs risks to confuse or mislead users with 
regard to the responsibility of the platform in case of problems with the P2P transaction. 

Price transparency 

The search results on many platforms do not give the total price; notably platform fees 
which range from 10% to 25% are often added only at the booking stage. Among the 10 
case  study  platforms  where  this  in-depth  analysis  was  carried  out,  only  the  French 
language version of BlaBlaCar displayed prices in search results including the transaction 
fee. 

Algorithms are increasingly used to determine (recommended) prices, especially by large 
platforms. But there is no detailed information on how these prices are calculated. In the 
case of algorithms setting the prices for listings this means peers have no or little leeway 
to  modify  them.  With  dynamic  pricing  mechanisms  prices  may  change  without  peers 
understanding why this is the case.  

Data use and reuse 

There  is  a  lack  of  information  about  data  use  and  reuse,  data  transfer  or  resale. 
Platforms  gather  a  large  amount  of  data  from  their  users:  not  only  basic  user 
information, but also data on behaviour, trends or frequency of transactions. There is a 
growing  trend  among  platforms  to  use  that  data  for  ‘dynamic’  pricing  or  to  encourage 
peers to engage in a transaction on the platform. While some of these data can facilitate 
solving of consumer issues, current practices, or lack of clarity about current practices of 
data  use  and  reuse  also  raise  concerns  regarding  the  protection  of  personal  data, 
especially  when  they  are  shared  and/or  transferred  to  third  parties  for  commercial 
purposes.  

No  information  was  obtained  on  the  monetisation  of  user  data.  Most  platforms  do  not 
have a clear data use policy regarding transfers to third parties. All platforms covered in 
the in-depth case study analysis indicate they share data with third parties, but they do 
not  always  mention  that  they  only  do  so  with  user  consent.  Only  BlaBlaCar  mentions 
explicitly that they do not sell data to third parties. 

These  findings  are  particularly  in  the  light  of  the  survey  and  focus  group  results  which 
show that consumers are:  

  aware that they are not fully informed,  

  value clarity and transparency about their rights and obligations highly; and  

 

see a significant role for platforms in making such information available to them. 

D.  Trust building and verification of identity information on P2P platforms 

 
 
 
 
 
 
 
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While  conventional  businesses  generate  consumer  trust  through  compliance  with 
governmental  regulations,  platforms  seek  to  generate  trust  through  a  variety  of  trust-
building  tools.  The  results  of  the  screening  of  485  platforms, the  user survey and  focus 
groups, and the case studies, indicate that the core trust building tools, peer review and 
rating systems as operated by most platforms and their identity verification practices, are 
neither  fully  reliable  nor  transparent.  Their  effectiveness  is  therefore  subject  to  serious 
doubt. Moreover, many platforms do not offer these core trust building services.  

Peer review and ratings systems 

Peer  reviews/ratings  and  reputation  systems  are  the  most  prominent  “trust  building 
tools”  across  all  platforms  and  they  are  often  presented  by  platforms  as  their  main 
instrument  for  protecting  peer  consumers  and  peer  providers  against  fraud  and  other 
risks and for ensuring the quality of goods and services and reliability of providers.  

While about half (52%) of the 485 platforms screened for this study offer a peer review 
and rating system, almost half of them do not offer such service. User data checks and 
identity  verification  services  were  identified  on  only  25%  of  platforms.  Among  the  case 
study  platforms  nine  out  of  ten  manage  peer  rating  systems,  and  eight  out  of  ten  peer 
review systems.  

The  survey  findings  show  that  neither  peer  consumers  nor  peer  providers  use  peer 
reviews or ratings systematically. Only about 40% of peer consumers and peer providers 
use  reviews  regularly.  Among  those,  more  peer  consumers  consult  reviews  before  the 
transaction  than  write  reviews  afterwards;  for  peer  providers  no  such  difference  was 
found.  This  indicates  that  reviews  are  unlikely  to  reflect  the  experience  of  all  platform 
users,  but  rather  to  represent  those  of  a  smaller  number  of  more  involved  peers.  In 
particular,  as  only  20%  of  peers  said  they  left  a  negative  review  or  rating  after 
encountering  a  problem  with  a  transaction,  there  are  indications  that  rating  and  review 
systems may be biased.  

The limited use of review and rating systems may be at least in part explained by a lack 
of  confidence  in  these  systems.  The  survey  shows  that  most  peer  consumers  evaluate 
user  review  systems  positively  in  terms  of  added  safety  and  protection,  easy  access  to 
adequate information and as instrumental to increasing trust in the platform. But at the 
same time three quarters of peer consumers have at least some reservations about the 
reliability  of  user  review  systems  and  their  ability  to  generate  trust,  provide  adequate 
information, safety and protection. It also appears from the findings on problem solving 
that writing bad reviews or giving low ratings is not a successful strategy to get problems 
solved.  

The  focus  group  research  indicates  that,  instead  of  relying  only  on  peer  reviews  and 
ratings, peers evaluate the overall reliability of a platform and of its peer providers based 
on a combination of elements. 

The case studies provide further insights into the management of peer review and rating 
systems which raise further questions about their transparency, reliability and neutrality. 

  All  case  study  platforms that  manage  review  systems  reserve  the  right  to  delete 

reviews if they do not respect certain standards  

  Only two platforms systematically check reviews before publication, and two other 
platforms  monitor  reviews  after  publication  through  key  word  searches.  On  the 
other  platforms,  it  is  not  clear  whether  there  is  any  systematic  monitoring  of 
reviews or whether platforms rely on peers to signal suspicious content. 

  None  of  the  case  study  platforms  give  information  to  users  about  the 
representativeness  and  reliability  of  user  reviews  or  ratings,  although  they  hold 
the  data  to  establish  the  percentage  of  transactions  that  are  reviewed  and  the 
frequency of fake or fraudulent reviews. 

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  Most  platforms  do  not  inform  users  if  positive  or  negative  reviews  or  ratings 
influence the search results or access to the platform; those platforms who inform 
these use ratings or reviews for these purposes, do not explain clearly how this is 
done.  

Finally,  cross-platform  portability  of  reputations  based  on  review  and  rating  systems 
remains  scarce,  although  there  are  number  of  market  operators  who  are  developing 
solutions to address this issue in the future. 

Verification of identity information  

The  case  studies  show  that  platform  checks  of  identity  information  submitted  by  peers 
remains,  in  most  cases,  quite  basic  and  almost  all  platforms  deny  responsibility  for  the 
accuracy  of  user  information.  Most  case  study  platforms  do  not  systematically  verify 
identity  data  of  users,  but  rely  one  user  information  checks  by  email  or  social  media 
accounts.  Some  offer  optional  identity  verification  services  and  very  few  require  official 
identity documents for registration.  

The lack of adequate identity verification raises concerns given that often people end up 
meeting  face-to-face,  geolocation  data  are  exchanged  among  platform  users  and  the 
other peer may not be identifiable in case something goes wrong with the transaction. 

E.  Access to complaints, redress and insurance 

Among  the  485  P2P  platforms  screened,  52%  offer  at  least  some  level  of  complaints 
handling, and 24% offer some form of insurance, either as part of the transaction fee or 
as an add-on service.  

All ten case study platforms offer some form of online channel for complaints, and seven 
out of ten include insurance covering peer providers against damages in the transaction 
fee.  All  platforms  websites  have  a  FAQ  section  with  advice  about  what  to  do  to  solve 
problems.  But  only  five  out  of  ten  give  guidance  on  what  to  do  in  case  something  is 
wrong with the performance of the service, the product or its delivery. 

A majority of case study platforms also manage “redress policies” and actively intervene 
to  remedy  problems  with  the  transaction.  Several  et  out  clear  rules  regarding 
cancellations  and  some  criteria  for  returns  and  refunds.  However,  most  platforms  issue 
refunds at their own discretion in cases of goods and services that are of poor quality or 
not  as  described.  None  of  the  platforms  sets  out  clearly  the  responsibility  they  assume 
for handling complaints in case something goes wrong. 

Although most larger platforms offer some form of insurance to peer providers, the scope 
of  its  coverage  varies  significantly  between  platforms.  The  main  issue  with  insurance 
cover is the lack of information on what exactly is covered and how the validity of claims 
is assessed.  

F.  Regulatory elements in practice 

Nature of the transaction  

Distinguishing  between 
in  a 
commercial/professional capacity and individuals acting in a private capacity is essential 
to determine whether consumer law and marketing law applies.  

traders  and  consumers,  between 

those  acting 

The  Legal  Analysis  finds  that  although  the  terminology  used  by  different  national  legal 
instruments  is  not  always  completely  uniform,  definitions  of  ‘trader’  and  ‘consumer’  are 

 
 
 
 
 
 
 
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substantively  equivalent,  both  in  national  consumer  law  and  in  national  Commercial 
Codes, and reflect those in the EU consumer acquis.  

Indicators of what constitutes a trader vary from Member State to Member State and are 
rarely defined in national legal instruments. The ‘continuity’ and the ‘professional nature’ 
of the activity are the two main elements on basis of which Member States assess, on a 
case-by-case basis, whether an individual is acting in a private capacity or as a trader.  

Some Member States have tried to clarify whether an individual is acting in a private or 
commercial/professional  capacity  by  setting  out  sector-specific  thresholds  and/or  tax 
thresholds.  These  limits  differ  from  sector  to  sector  and  between  countries,  or  even 
regions  and  cities.  They  are  not  necessarily  relevant  for  distinguishing  consumers  from 
traders for consumer law purposes or determining the applicability of consumer  

This  lack  of  clarity  and  fragmentation  -  though  mostly  related  to  market  access  issues 
and, therefore, outside the scope of consumer policy - generates legal uncertainty about 
the  applicability  of  consumer  protection  rules  and  could  consequently  hinder  consumer 
protection  

C2C legislation and its enforcement 

In most Member States, the main provisions applicable to C2C transactions falling within 
the  scope  of  this  study  consist  in  national  Civil  Code  rules.  General  civil  code  rules 
provide a basic level of protection to parties to C2C contracts. However general civil law 
provisions  are  not  usually  tailored  to  C2C  transactions  concluded  online  via  platforms. 
Civil  law  rules  applicable  to  C2C  transactions  presume  that  both  parties  to  the  contract 
meet in person or that the good is physically present. When a C2C contract is concluded 
online via a platform, however, usually the parties do not physically meet or the good is 
not  physically  present,  and  terms  and  conditions  of  the  contract  may  have  been 
predetermined by one of the parties or the platform. The Legal Analysis therefore found 
that  Member  States’  civil  provisions  are  generally  not  tailored  to  C2C  transactions 
concluded  online  via  platforms,  because  national  civil  codes  generally  date  from  before 
the digital  

The  Legal  Analysis  found  that  the  main  issue  concerning  the  existing  C2C  legislation 
consists  in  its  scarce  enforcement  in  the  P2P  markets  context.  The  competence  of  the 
national  consumer  protection  authorities  is  generally  limited  to  the  B2C  scenario.  To 
enforce  rules  applicable  to  C2C  transactions.  The  case  must  be  brought  before  civil 
courts.  Civil  claims  are  rare  due  to  the  high  costs  and  length  of  civil  proceedings 
compared  to  the  average  low  value  of  C2C  contracts  on  online  platforms.  The 
enforcement  of  C2C  legislation  is  also  hindered  by  the  scarce  collaboration  between 
online P2P platforms and competent authorities.  

Platform transparency  

One  of  the  main  issues  concerning  the  relationship  between  platforms  and  their  users 
relates to the lack of transparency in online P2P platforms’ rules and practices. According 
to the national Legal Analysis, most platforms qualifying as ‘traders’ and engaging in B2C 
commercial  activities  may  not  comply  with,  for  example,  some  of  the  professional 
diligence duties set out by Article 5(2) of the UCPD.  

Consequently, where platforms do not enable their users to clearly indicate that they act 
in  a  professional/commercial  capacity  or  do  not  clarify  that  consumer  protection  law 
exclusively applies when the transaction is concluded with a trader, this could represent a 
breach of a due pre-contractual information requirement 

 As  the  case  studies  have  shown,  some  of  the  largest  platforms  allow  commercial  peer 
providers to operate alongside private peers without distinguishing between them – while 
others do require them to indicate the commercial or professional nature of their activity.  

The Legal Analysis also found that most platforms set minimal identification requirements 
for  registration  and  access  (e.g.  name  and  email  address),  and  usually  do  not  adopt 
adequate  measures  to  verify  users’  identity.  The  professional  diligence  duties  and  the 
transparency  requirements  of  the  UCPD,  as  interpreted  in  the  UCPD  Guidance,  refer  to 
checking  user  identity  for  example  when  considering  that  platforms  should  ensure  that 
reviews originate from real users and are not fake. 

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Platform liability  

All  case  study  platforms  exclude liability  for  the  veracity  of  information  provided  by  the 
peer to establish whether they are a commercial or a private provider.  

Regarding  responsibility  (liability)  in  case  of,  for  example,  non-performance,  non-
compliance  of  the  performance  by  the  peer  suppliers,  or  technical  problems,  the  Legal 
Analysis shows that in most Member States, platforms’ terms and conditions exclude any 
liability  of  the  platform  in  relation  to  the  contracts  concluded  between  the  peers,  and 
explicitly state that the platform is not a party to such contracts. This result is confirmed 
in the in-depth analysis of individual platforms in the case studies. 

The above results highlight two main issues for peer consumers: 

 

If  the  platform  actively  manages  or  governs  the  transactions  concluded  between 
peers, this might mislead users by creating the false impression that the platform 
shares  a  certain  degree  of  responsibility  in  case  of  non-performance  or  non-
compliance of the performance.  

  Lack  of  clarity  regarding  the  contractual  nature  of  the  peer  to  peer  transaction 
combined  with  exclusion  of  liability  by  the  platform  may  leave  some  peer 
consumers unknowingly without adequate protection. 

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CONSUMER ISSUES & POLICY OPTIONS 

As  the  above  findings  show,  the  emergence  and  development  of  online  peer  to  peer 
markets has both positive and negative effects on consumers.  

On  the  one  hand,  the  use  of  new  technologies  by  online  platforms  has  the  potential  to 
enable efficient matching of supply and demand (e.g. reducing costs and enabling private 
individuals  to  monetise  their  under-utilised  resources),  reduce  information  asymmetries 
and provide opportunities for new employment.197  

On the other hand, the  study points to five key consumer issues that emerge from this 
new kind of economy: 

1.  Transparency  and  clarity  regarding  the  nature  of  the  transactions  concluded 
through  online  P2P  platforms,  applicable  consumer  rights  and  obligations,  the 
applicable legal framework and its enforcement; 

2.  Reliability of peer review and rating systems and accuracy of identity information 

provided on the platform; 

3.  Discrepancy  between  exclusion  of  platform  responsibility  and  liability  for  the 

performance of online P2P transactions and platform practices; 

4.  Access to redress for peer consumers and peer providers; and 

5.  Data use and data protection issues. 

If  left  unchecked,  these  problems  might  end  up,  hampering  ‘the  development  of  the 
collaborative economy in Europe’ and preventing ‘its benefits from materialising fully’.198 
This  is  all  the  more  important  given  the  rapid  development  and  the  expected  future 
growth  trajectory  of  P2P  platforms  in  terms  of  services  offered,  number  of  users  (both 
peer consumers and peer providers) and the economic importance of the market.  

At the same time, stakeholder engagement over the course of this study has uncovered a 
lack of consensus regarding the best way forward. While some stakeholders (including, in 
particular,  representatives  of  online  P2P  platforms)  advocate  self-regulation  and  claim 
that  new  legal  initiatives  would  represent  an  unnecessary  regulatory  obstacle  to  the 
development  of  online  P2P  markets,  others  call  for EU  or national  level  initiatives  (legal 
or non-legal) to allow the peer to peer economy to fully develop its potential benefits for 
consumers.  

As the literature review indicates, some of the consumer issues that arise on online P2P 
platforms  may  be  solved  through  self-regulation  by  the  P2P  platforms  and  greater 
transparency  about  rights,  obligations  and  responsibilities.  However,  self-regulatory 
approaches  of  platforms  towards  peers  are  as  the  study  has  shown,  often  optional  and 
voluntary,  and  mainly  rely  on  incentives  rather  than  systematic  enforcement  or 
sanctions199.  Self-regulatory  measures  alone  might  not  be  enough  to  address  the 
externalities  deriving  from  the  platforms’  operation,  since  addressing  such  impacts  may 
not directly promote transactions on the platform200 - which is a main source of revenue 

197 Commission Staff Working Document accompanying the document Communication from the Commission to 
the European Parliament, the Council, the European Economic and Social Committee and the Committee of the 
Regions,  ‘A  European  agenda  for  the  collaborative  economy’,  supporting  analysis,  2.6.2016,  SWD  (2016)  184 
final, p. 6. 
198 OCU, Altroconsumo, Deco Proteste, Test Achats/Test Ankoop, Cibersomosaguas, Ouishare, ‘Collaboration or 
Business? Collaborative consumption: From value for users to a society with values’ [2016] OCU Ediciones, p.2. 
199 E.g. through additional benefits to peers that comply, such as AirBnB’s super host badge, or Peerby’s green 
verification circle – see Task 4 case studies. 
200 US Federal Trade Commission (2016). The “Sharing Economy”. Issues Facing Platforms, Participants & Regulators. 
An FTC Staff Report. Available at: https://www.ftc.gov/system/files/documents/reports/sharing-economy-issues-
facing-platforms-participants-regulators-federal-trade-commission-
staff/p151200_ftc_staff_report_on_the_sharing_economy.pdf  

 
 
 
 
 
                                                 
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of  the  major  platforms.  Platforms  may  therefore  have  little  incentive  to  self-regulate 
issues that impose costs only on third parties, but both the platform and peer providers 
may have an interest in addressing such harms if they could be liable to third parties for 
such harms 201.  

The  remainder  of  this  Section  proposes  a  set  of  potential  options  for  addressing  the 
consumer issues identified above. 

A.  Transparency and clarity  

Contractual nature of the transaction 

As  several  Sections  of  this  Report  have  pointed  out,  online  P2P  markets  blur  the  line 
between  traders  and  consumers.  The  general  definitions  of  ‘trader’  and  ‘consumer’  are 
applied  by  Member  States’  on  a  case  by  case  basis  using  different  indicators  to 
distinguish  traders  from  consumers  by  sector.  Such  fragmentation  generates  legal 
uncertainty and lack of clarity about the applicability of consumer and marketing law. 

There  is  no  consensus  amongst  stakeholders  on  how  to  clarify  the  distinction  between 
traders and consumers and reduce legal uncertainty.  Some of the options suggested by 
stakeholders for addressing this issue include:   

  At  a  minimum,  broaden  the  political  debate  on  this  point  until  agreement  is 
reached  and  monitor  legal  initiatives  adopted  at  Member  State  level  and 
assess their effective functioning; 

  Defining  at  EU  level  a  harmonised  set  of  indicators  that  help  distinguish 

traders from consumers; 

  Promoting  legal  initiatives  at  national  and  local  level  aimed  at  setting  out 
sector-specific or tax thresholds that help distinguish between professional and 
non-professional  activities,  or  between  businesses  and  private  individuals  for 
tax purposes;   

  Acknowledging at national level the existence of a new statute of ‘prosumers’ 
or  of  'microentrepreneur',  as  used  in  France202,    as  new  types  of  economic 
operators. 

Irrespective  of  the  actual  definition  of  traders  and  consumers,  the  study  shows  that 
platforms lack transparency in providing information on the status of peers operating on 
their  platforms.  Some  of  the  larger  online  P2P  platforms  do  not  enable  or  require  peer 
providers  to  specify  whether  they  are  acting  as  traders  or  as  consumers,  while  others 
require clarity and/or indicate the peer’s (self-declared) status clearly to peer consumers.  

One option to address this issue would be to require all platforms to clearly indicate the 
(self-declared)  status  of  the  peer  provider  to  users  at  each  stage  (before,  during  and 
after)  of  the  transaction,  and  to  specify  that  consumer  protection  laws  will  exclusively 
apply where the transaction is concluded with a trader. As platforms possess the data to 
assess relevant indicators, such as frequency of transactions and number of listings, they 
can also monitor the validity of this information.  

Consumer knowledge of their rights and obligations  

201 US Federal Trade Commission (2016). The “Sharing Economy”. Issues Facing Platforms, Participants & Regulators. 
An FTC Staff Report. Available at: https://www.ftc.gov/system/files/documents/reports/sharing-economy-issues-
facing-platforms-participants-regulators-federal-trade-commission-
staff/p151200_ftc_staff_report_on_the_sharing_economy.pdf  
202 not to be confounded with the existing legal category of "micro-enterprise"  

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The survey and focus groups have shown that most peer consumers and peer providers 
are not aware or uncertain of their rights and responsibilities in P2P transactions or who 
to turn to when something goes wrong. At the same time a very large majority of peers 
find  it  important  or  very  important  that  P2P  platforms  are  clear  and  transparent  about 
such. There is therefore a need for platforms to improve and clarify the information they 
give to their users.  

First  of  all,  this could  be  addressed  by  platforms  by  making  their Terms and  Conditions 
more  user-friendly203  and  by  ensuring  that  platforms  present  relevant  information  not 
only in separate, lengthy T&Cs, but at the moment when this information is most useful 
to their users (e.g. at specific points before, during and after the transaction).  

Second,  platforms  should  ensure  that  peer  consumers  receive  pre-contractual 
information  when  they  engage  in  transactions  with  commercial  peer  providers  on  the 
platform. 

Third,  platforms  should  inform  their  users  where  they  can  find  information  about 
applicable licensing and/or authorisation requirements, as well as registration obligations 
set  out  by  national/local  legislation  (e.g.  possible  income  thresholds  or  temporal 
thresholds set out in the accommodation sector).  

Finally, in addition to requiring platforms to present key information more clearly and at 
the  point  in  time  when  this  information  is  most  useful,  an  awareness  raising  campaign, 
ideally  carried  out  in  cooperation  with  online  platforms  themselves,  could  further  boost 
online P2P user knowledge about their rights and responsibilities.  

Applicable C2C legal framework   

In most EU countries, the legal framework applicable to C2C transactions is not tailored 
to  contracts  concluded  online  through  P2P  platforms.  For  example,  in  C2C  transactions 
concluded  online  or  via  online  platforms  in  most  cases,  the  parties  or  the  good  are  not 
physically present, the identity of the other peer is often not clear, and part of the terms 
of the contract may be determined by the platform.  

While no extra regulation is necessary with regards to C2C contracts concluded between 
two  parties  whose  identity  as  consumers  is  clear,  in  cases  of  C2C  contracts  concluded 
online,  it  could  therefore  be  beneficial  to  make  existing  C2C  legislation  fit  for  digital 
purposes. For example, a recent amendment to the French Civil Code introduced a new 
provision204  setting  out  that  unfair  contract  terms  included  in  ‘adhesion  contracts’  (i.e. 
contracts  whose  content  has  been  pre-formulated  by  one  of  the  parties)205  are  void.  It 
could for example be assessed whether certain aspects of national unfair contract terms 
legislation  applicable  to  B2C  transactions  could  be  extended  to  online  C2C  contracts 
where  the  content  of  the  contract  is  to  a  large  extent  pre-determined  by  one  of  the 
parties, or by a third party, i.e. the platform, the parties or of the object of the contract 
are  not  physically  present  and  there  are  uncertainties  relating  to  the  actual  identity  of 
one of the parties. 

Enforcement issues 

The  main  issue  concerning  the  existing  legal  framework  applicable  to  C2C  transactions 
relates to the absence of easily accessible enforcement options. In order to enhance the 

203 
http://ec.europa.eu/consumers/consumer_evidence/behavioural_research/docs/terms_and_conditions_final_re
port_en.pdf 
204 New Article 1171 of the French Civil Code, as amended by Ordinance No. 2016-131.   

205 New Article 1110 of the French Civil Code, as amended by Ordinance No. 2016-131.   

 
 
 
 
 
                                                 
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effective enforcement of existing C2C legislation, the following options were proposed for 
consideration by stakeholders: 

1.  Expanding  the  competence  of  national  consumer  protection  authorities  to  C2C 

transactions on online platforms;206  

2.  Encouraging  stakeholders  other  than  platforms,  such  as  consumer  organisations 
to raise awareness among consumers of their rights and obligations, for example 
by making appropriate funding available; 

3.  Promoting  the  use  of  the  European  Small  Claims  Procedure  on  online  P2P 
platforms for C2C disputes with a cross-border element and up to EUR 2,000; 

4.  Expanding  the  scope  of  application  of  national  small  claims  procedures  to  C2C 

disputes (where small claims procedures exist); 

5.  Encouraging  platforms  to  collaborate  with  competent  authorities  to  facilitate 

peers’ compliance with local regulation.  

B.  Consumer  trust  and  accuracy  of  user  generated  information  on  the 

platform 

The  study  has  shown  that  trust  is  a  key  issue  for  users  and  platforms  in  online  P2P 
markets. Furthermore, there are significant concerns regarding current platform and user 
practices which have the potential to undermine trust, mislead consumers and stifle the 
development of online P2P platforms. 

Peer review, ratings and reputation tools 

The  study has  found that  online  P2P  platform users  do  not  use  peer reviews  and  rating 
systems  systematically  and  that  they  do  not  always  trust  them.  In  addition,  most 
platforms  do  not  appear  to  monitor  systematically  whether  reviews  or  ratings  are 
generated  by  actual  and  genuine  users.  Given  the  significant  issues  related  to 
transparency  and  clarity  of  information  on  P2P  platforms,  these  tools  are  not  effective 
alternatives to regulation in the current environment.  

In line with the guidance on the UCPD, and as for example proposed in the French Digital 
Republic Law,207, there is a need for platforms to be transparent about the mechanisms 
they use to manage review and rating systems, and to ensure consumer understanding 
of the underlying quality control system.  

One option, along the same lines as the Key Principles for Comparison Tools208 published 
by the European Commission in 2016, would be to require platforms, which feature peer 
review, rating or reputation systems, at a minimum, to:  

  be  clear  and  transparent  about  how  reviews  are  created,  posted,  ranked  and 

sorted;  

  publish only genuine reviews, including all genuine negative reviews;  

  publish reviews without unreasonable delay;  

206  Conclusions  of  stakeholders  attending  the  Workshop  carried  out  in  Brussels,  as  part  of  the  study,  on  3 
October 2016. 
207https://www.legifrance.gouv.fr/affichLoiPubliee.do?idDocument=JORFDOLE000031589829&type=general&leg
islature=14. 
208 ec.europa.eu/consumers/consumer.../key_principles_for_comparison_tools_en.pdf 

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 

indicate the date of publication and any updates/edits; 

  be clear and transparent about whether the reviews have been verified; and  

  what the method of verification was.  

Furthermore, peers whose online reviews have not been published should be made aware 
of  the  reasons  for  the  rejection,  given  the  possibility  to  object  to  this  refusal  and 
provided a facility to report doubts about the authenticity of a review. 

Platforms  managing  peer  review  and  rating  systems  could  also  be  required  to  give 
information  to  users  about  the  representativeness  and  reliability  of  user  reviews  or 
ratings, and on how positive or negative reviews or ratings influence the search results or 
access to the platform.   

Accuracy of identity information  

The study shows that most platforms do not verify peer generated identity information. 
One  option  to  deal  with  this  issue  would  be  to  require  that  platforms  which  actively 
manage,  or  govern  the  transactions  concluded  between  their  users,  to  adopt  tools  that 
help  to  adequately  ascertain  the  users’  identity.  This  may  for  instance  include  ID 
verification  systems  to  check  peers’  identity  at  the  time  of  registration,  interviews, 
checks against official databases or similar means. This could build on the references to 
user identity checks in the UCPD Guidance, which already foresees that platforms should 
take steps to ensure that reviews originate from real users if presented as such.209  

C.  Platform  responsibility  and  liability  for  the  performance  of  the  P2P 

transaction  

As  this  study  shows,  the  emergence  of  the  P2P  platform  economy  gives  rise  to  many 
questions about the liability of the parties involved, i.e. the platform and its users. Most 
importantly, in the current legal environment there is significant lack of clarity about the 
liability  of  platforms  that  do  more  than  mere  hosting  of  listings  –  which  as  the  study 
shows  includes  a  majority  of  the  larger  platforms  operating  in  the  EU.    This  concerns 
issues  of  liability  for  unlawful  behaviour  of  users  on  the  platform,  such  as  illegal 
transactions,  posting  false  and  misleading  advertisements  and  reviews,  and  non-
performance or poor performance of transactions.  

The study has identified widespread use of terms and conditions explicitly excluding the 
platform’s liability for the behaviour or transactions between peers. At the same time, the 
business models of the largest online P2P platforms are built on the volume and value of 
P2P  transactions  they  facilitate,  and  on  their  at  least  partial  control  over  the  terms  and 
quality of these P2P transactions.  

Depending  on  the  extent  to  which  a  platform  ‘intervenes’  in  the  transactions  concluded 
by its users, the latter may expect that the platform shares responsibility with the peers 
in  case  of non-performance  or  non-compliance  of  the  performance. For  example,  where 
the  platform  actively  manages  P2P  transactions  (e.g.  facilitating  trust  among  peers  by 
using or suggesting ID verification systems, managing user reviews, mediating disputes) 
or governs them (e.g. setting cancelation policies, providing insurance and refunds), it is 
more likely that its users have the impression that the platform will also share a certain 
degree of liability. 

Some  of  the  following  options  suggested  by  stakeholders  might  be  considered  in 
addressing this issue:  

209 UCPD Guidance, 25.5.2016, COM (2016) 320, supra, p. 137. 

 
 
 
 
 
 
                                                 
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1.  Clarify  the  interpretation  of  the  already  existing  obligations  arising  from  EU 
legislation, notably with respect to platforms that actively manage and govern the 
transaction between the peers. 

2.  Take  legal  initiatives  at  EU  level  to  tailor  the  responsibility  of  the  platform  in 
relation  to  the  transactions  concluded  between  the  peers  to  its  degree  of 
intervention, management or governance of the P2P transaction.  

3.  Test  the  effectiveness  of  existing  platform  Codes  of  Conduct210,  either  at 

European, national or industry level. 

D.  Access to redress  

The  results  of  this  study  have  shown  that  redress  and  refunds  in  case  something  goes  
wrong is often left to the discretion of the platform which evaluates complaints on a “case 
by case” basis, and that the criteria for such decisions are not clearly explained to peers. 

One  options  to  be  considered  to  address  this  issue  is  requiring  platforms  which  govern 
P2P transactions (business model 3) to offer clearly explained, platform-managed redress 
options  to  peer  consumers  and  peer  suppliers  in  case  of  disputes.  This  is  supported  by 
the  results  of  the  consumer  survey  which  finds  that  peers  (both  providers  and 
consumers) consider the platform to be an important channel for resolving issues in the 
P2P transaction.  

At a minimum, all platforms should in their terms and conditions: 

 

 

 

set  out  clearly  the  rules  that  apply  in  case  of  cancellations  of  transactions, 
including entitlements to refunds and any administrative or cancellation fees; 

inform about any right to withdrawal from transactions, including entitlements to 
refunds and any administrative fees;  

inform about the rules that apply in case of non-performance or poor performance 
of the transaction, or if the good or service does not fit the description, including 
entitlements to refunds and any administrative fees. 

Furthermore,  all  platforms  should  also  inform  peers  about  external  informal  and  formal 
redress,  including  when  relevant Alternative Dispute  Resolution  and  cross  border Online 
Dispute Resolution.  

E.  Data (re)use and data protection   

As the survey and focus group results have shown, transparency about the personal and 
behavioural data that platforms collect, how they use them, who they share them with or 
sell  them  to,  as  well  as  information  about  data  protection  rules  that  apply  is  of  utmost 
important for both peer providers and peer consumers.  

Data  use  and  reuse  are  common  among  the  platforms  analysed  in  this  study  and  an 
essential  part  of  their  business  models.  Especially  in  the  case  of  larger  platforms  these 
user  data  represent  significant  value,  for  the  platform  itself  as  well  as  for  third  parties, 
for  price  setting,  marketing  and  other  commercial  and  public  policy  purposes.  But  the 
information given by platforms about their data use, re-use, sharing and selling practices 

210  Information  collected  through  consultation  with  national  stakeholders  (Spain:  Blog  Ecolaborativa,  24  May 
2016; Spanish Association of Digital Economy, 24 May 2016; National Commission on Markets and Competition, 
26 May 2016; Consumers’ and Users’ Organisation, 2 June 2016; Ireland: Lecturer of Law at NUI Galway, 14 
June  2016;  Finland:  Consumer  Ombudsman,  20  May  2016,  and  the  Consumer  Union,  18  May  2016).  This 
argument  has  also  been  supported  by  stakeholders  attending  the  European  Consumer  Summit  of  17  October 
2016 in Brussels. 

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is in many cases not fully transparent, and it is therefore not clear if current national data 
protection rules are fully respected currently. 

As  of  25  May  2018,  platforms  will  need  to  comply  with  new  obligations  set  out  by  the 
General  Data  Protection  Regulation  (GDPR)  .  It  is  suggested  that  the  accompanying 
measures to facilitate the implementation of the GDPR include specific measures focusing 
on its implications for online P2P platforms.   

F.  Further research 

Several  areas  highlighted  over  the  course  of  this  study  could  either  not  be  fully 
addressed  within  the  present  research  or  would  require  further  study  to  develop 
appropriate policy options: 

1.  A  large  set  of  consumer data  was collected  as part  of  this study  and  –  though  a 
comprehensive analysis was conducted within the scope of the research questions 
for  this  Report,  further  analysis  could  yield  interesting  results  regarding  the 
differences  between  individual  platforms,  the  characteristics  of  consumers  who 
are  active  in  P2P  markets  and  the  drivers  of  their  behaviour/perceptions.  In 
particular,  further  analysis  should  go  beyond  descriptive  statistics  to  develop 
econometric models of: 

  Drivers  of  participation  in  P2P  transactions,  how  this  relates  to  spending 

patterns, whether it differs across platform business models; 

  Occurrence,  nature  and  resolution  of  problems  and  how  this  links  to 
different platforms and the three business models identified in this study; 

  Differences in perception among peer consumers regarding the role of the 
platform  in  the  P2P  transaction  and  the  business  models  identified  in  the 
study; or 

  Any  correlations  between  the  above  and  the  regulatory  regime  in  the 

country where the peer resides. 

Such an analysis would develop robust quantitative estimates of the strength and 
importance  of  any  associations  between  consumer  behaviour/perception  and  the 
business  models  described  in  the  study.  It  would  test  the  relevance  of  the  three 
business  models  in  terms  of  consumer  behaviour  and  thereby  help  understand 
whether/how these business models can inform future consumer policy.  

2.  In  the  field  of trust-enhancing  tools,  which  could  be  one of  the  key  elements  for 

protecting users in the platform economy, additional research could:  

 

 

Investigate in greater detail the effectiveness of various tools in protecting 
users from fraud and other risks and for ensuring the quality of goods and 
services, and the extent to which such systems determine consumer trust 
in P2P platforms.  

Investigate  the  development  of  the  market  for  such  tools  and  their 
adoption  by  platforms  and  quantify  the  link  between  trust-enhancement 
and platform growth to develop the business case (financial and strategic) 
for different types of trust tools.  

 

Investigate mechanisms for reputation portability, assessing its advantages 
and disadvantages and technical, legal and practical feasibility.  

3.  From  a  legal  perspective,  the  current  research  could  be  extended  to  analyse  the 

following aspects in greater depth:  

 
 
 
 
 
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  The  extent  to  which  the  European  Small  Claims  Procedure  is  or  can  be 
used  for  C2C  disputes  with  a  cross-border  element  and  up  to  EUR  2,000 
EUR, in particular;  

  The  scope  and  the  thresholds  for  access  to  national  small  claims 
procedures and their relevance/effectiveness for disputes with transactions 
on online P2P platforms;  

  Risks  and  benefits  of  a  specific  consumer  law  regime  applicable  to  new 
types of economic operators in the P2P platform economy such as  ‘micro-
entrepreneurs’ or ‘prosumers’. Mapping existing legal initiatives would help 
assess related advantages and disadvantages. 

4.  As regards data use and data protection, further research could look into:  

  The  use  of  data  by  platforms  themselves,  for  example  for  price  setting 
purposes, and their data sharing, transfer and selling practices, is required 
to assess potential data protection issues.  

  The access platforms have to data held by other public and private (credit 
ratings, Facebook accounts, commercial 'verification' companies data sets) 
sources;  

  The issues surrounding the transfer of data by platforms to authorities and 
the  clarity  of  information  to  users  about  the  transfer  of  personal  data  of 
peer providers to authorities for the purpose of verifying compliance local 
or national legal measures such as income or temporal thresholds. 

5.  Given  that  the  current  estimates show  a  large  gap between  total  estimated peer 
expenditure  and  total  estimated  peer  revenues  in  all  sectors,  except  in  ride 
sharing/hiring, further research is necessary to disaggregate "non-peer revenues" 
data  into  platform  revenue,  revenue  for  third  parties,  additional  cost  elements 
such  as  tourist  taxes,  cleaning  costs  and  others,  as  well  as  the  impact  of 
underreporting of peer provider revenue. 

6.  As the use of apps by P2P platform users is likely to increase, data about app use 
will become an important source for obtaining insights into the functioning of P2P 
platform markets. Further research into both quantitative and qualitative aspects 
of transactions via apps will therefore become increasingly relevant.  

7.  Finally,  going  further  beyond  the  scope  of  the  present  research  focused  on  P2P 
markets,  there  is  a  need  to  analyse  the  implications  of  the  online  platform 
economy for consumers more generally. For instance:  

  The way in which platforms rank and present matching and search results 
to  their  peers  is  an  important  determinant  of  market  outcomes  for  the 
peers  and  the  underlying  algorithms  are  not  in  the  public  domain. 
Systematic research into how the characteristics of peers, their behavioural 
and  purchasing  data,  rating  and  preferences  affect  outcomes  such  as 
search results, prices, and other matters would be useful. 

  The emergence of a small number of very large platforms in some sectors 
has  led  to  questions  about  the  nature  of  competition  between  those  very 
large  P2P  platforms  and  traditional  businesses,  between  P2P  platforms 
themselves  and  between  peers  within  some  of  the  larger  platforms. 
Analysing  margins  for  larger  platforms  and  for  individual  peers;  network 
and  scale  effects  for  both  peers  and  platforms  and  potential  “tie-ins”;  as 
well as reputation portability for peers and the impact that this could have 
on competition would be important topics for further study. 

132 

 
 
 
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12 Annexes 

12.1 Annex1: Task 1 Report 

Submitted in a separate document. 

12.2 Annex 2: Task 2 Report  

Submitted in a separate document. 

12.3 Annex 3: Task 3 Report 

Submitted in a separate document. 

12.4 Annex 4: Task 4 report 

Submitted in a separate document. 

12.5 Annex 5: Task 5 Report 

Submitted in a separate document. 

12.6 Annex 6: List of platforms considered in Task 1 

Submitted in a separate document.  

12.7 References 

12.7.1 Academic literature  

Allen, D. and Berg, C., (2014). The sharing economy. How over-regulation could destroy 
an 
at:  
revolution. 
https://ipa.org.au/portal/uploads/Sharing_Economy_December_2014.pdf  

economic 

Available 

Balaram B., (2016). “Fair share. Reclaiming power in the sharing economy”, RSA Report. 
Available 
https://medium.com/rsa-reports/fair-share-reclaiming-power-in-the-
sharing-economy-499b46bd4b00#.a95g35stt 

at: 

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Case  5500/R/0052018/15,  Decision  of  the  District  Court  of  Helsinki  in  the  case  of 
Yahyobek Adhamov, Decision of 6 April 2016, appeal pending. 

Chapter 409 of the Laws of Malta, Act XII of 1999 as last amended by Act XXIII of 2009. 

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European  Economic  and  Social  Committee  and  the  Committee  of  the  Regions,  “A 
European agenda for the collaborative economy”, 2.6.2016, COM (2016) 356 final. 

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European  Economic  and  Social  Committee  and  the  Committee  of  the  Regions.  A  Digital 
Single Market Strategy for Europe, COM (2015) 0192 final.  

Directive  2000/31/EC of  the European  Parliament  and  of  the Council  of  8  June  2000  on 
certain legal aspects of information society services, in particular electronic commerce, in 
the Internal Market. 

Directive  2005/29/EC  of  the  European  Parliament  and  of  the  Council  of  11  May  2005 
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Directive 2011/83/EU of the European Parliament and of the Council of 25 October 2011 
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digitali  per  la  condivisione  di  beni  e  servizi    e  disposizioni  per  la  promozione 
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funzioni  provinciali  in  materia  di  turismo  in  attuazione  della  l.r.  22/2015.  Modifiche  alla 
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12.7.4 Online articles  

Anastasia, “Why the on-demand economy will continue to rise”, 12 June 2015. Available 
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Farrington, R., “College Students and the Small-Job Economy”, Forbes, 29 August 2015. 
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Keen, “Can the Sharing Economy Provide Good Jobs?”, The Wall Street Journal, 10 May 
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Lobo, S., “Auf dem Weg in die Dumpinghölle”, Der Spiegel, 3 September 2014. Available 
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Lundy,  L.,  “The  real  potential  of  blockchain  for  developers”,  IBM  Learn,  12  May  2016. 
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Morrissey,  J.,  “Sharing  Economy  Goes  Hyperlocal  With  a  Growing  Market  for  Household 
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colaborativo/resultados. 

Rachel Botsman website. Available at: http://rachelbotsman.com/thinking/ 

Service-Public-Pro.fr, Le site officiel de l’administration française website, “Déclaration de 
micro-entrepreneur 
https://www.service-
public.fr/professionnels-entreprises/vosdroits/F23264. 

(auto-entrepreneur)”. 

Available 

at: 

UK 
Sharing 
http://www.sharingeconomyuk.com/code-of-conduct.  

Economy 

website, 

“Code 

of 

Conduct”. 

Available 

at: 

Government 

UK 
Available 
“Introducing 
https://www.gov.uk/government/publications/introducing-govuk-verify/introducing-
govuk-verify 

website, 

verify”. 

GovUK 

at: 

140 

 
 
 
 
 
 
 
 
 
Exploratory study of consumer issues in online peer-to-peer platform markets –  
Final Report 

 
 
 
 
 
 
 
Exploratory study of consumer issues in online peer-to-peer platform markets –  
Final Report 

HOW TO OBTAIN EU PUBLICATIONS 

Free publications: 

•  one copy: 

via EU Bookshop (http://bookshop.europa.eu); 

•  more than one copy or posters/maps: 

from the European Union’s representations (http://ec.europa.eu/represent_en.htm);  
from the delegations in non-EU countries 
(http://eeas.europa.eu/delegations/index_en.htm);  
by contacting the Europe Direct service (http://europa.eu/europedirect/index_en.htm) 
or calling 00 800 6 7 8 9 10 11 (freephone number from anywhere in the EU) (*). 

(*)  The information given is free, as are most calls (though some operators, phone boxes or hotels may 
charge you). 

Priced publications: 

•  via EU Bookshop (http://bookshop.europa.eu). 

142 

 
 
 
 
 
 
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DOI: 10.2838/779064