bol.
Digital Services Act (DSA)
Context
The Digital Services Act introduced new European regulations requiring online marketplaces to clearly identify the responsible Economic Operator for every product offered on the platform. For bol, this meant that all partners must provide and maintain Economic Operator information for each offer, with a hard enforcement deadline of February 1, 2025.
This was not a surface-level compliance change. bol operates a shared product catalog where product data is aggregated across multiple partners. Introducing partner-specific responsibility data challenged the foundations of our existing data model, partner workflows, and technical architecture.
Failure to implement this correctly would put a significant portion of Gross Merchandise Value (GMV) at risk and expose the platform to legal consequences.
The challenge
The core challenge was twofold. First, Economic Operator responsibility is often legally ambiguous, especially for partners sourcing products from multiple suppliers, resellers, or manufacturers. Even partners consulting external legal bureaus struggled to determine who should be assigned as the responsible party.
Second, we needed to introduce this responsibility model into an ecosystem that spans:
The Seller Dashboard used by thousands of partners
A public API used by integrators and large sellers
The webshop, where partner-specific information must be displayed correctly
This meant designing a system that was legally compliant, technically scalable, and operationally realistic for partners with very different levels of maturity.
Strategic decision
Early in discovery, we identified two possible approaches.
One option was to add Economic Operator fields directly to each individual offer. This would be faster to implement, but would increase duplication, error rates, and long-term maintenance cost.
The second option was to create a centralized Economic Operator entity that partners could create once and then assign to multiple offers across their assortment, both in the Seller Dashboard and via the API.
Through interviews with partners and integrators, we learned that:
Partners reason about responsibility as a reusable concept, not as a per-offer detail
Bulk operations are essential for larger assortments
Integrators need a stable, entity-based model to automate compliance at scale
Based on these insights, we chose the centralized entity approach. This decision shaped the entire system and ensured it could scale beyond the initial regulatory requirement.
Designing the experience
I worked closely with multidisciplinary product, engineering, legal, and partner support teams to design a system that balanced clarity, control, and flexibility.
In the Seller Dashboard, partners could:
Create and manage Economic Operators in a dedicated settings area
Assign Economic Operators to offers individually or in bulk
Track compliance progress through clear visual indicators
We intentionally introduced progress feedback to reduce uncertainty and help partners understand how close they were to being compliant, rather than simply blocking them with errors.
For integrators and advanced partners, the same capabilities were exposed through the Retailer API, allowing Economic Operators to be created, updated, and linked programmatically.
On the webshop side, the system ensured that the correct Economic Operator information was displayed per partner-specific offer, even within a shared catalog environment.
Launch and learning
We launched the system on October 1st, well ahead of the final enforcement deadline. This allowed us to observe real partner behavior and identify friction while there was still room to adapt.
Within the first two weeks:
Over 75% of all active partners accessed the Seller Dashboard
Nearly 50% of them interacted with the new Economic Operator pages
More than 56% of those created at least one Economic Operator
84% of created operators were linked to at least one offer
Approximately 29% of GMV was already secured
On launch day, partner support cases increased by roughly 150 percent, clearly showing the impact and sensitivity of the change. This was expected and validated the decision to launch early rather than close to the enforcement deadline.
Research insights and iteration
Follow-up interviews with partners revealed several important insights:
Many partners complied even without fully understanding the legal rationale
Others struggled with responsibility assignment in complex supply chains
Clear progress indicators and bulk assignment flows were consistently praised
Larger partners managing multiple regional accounts requested synchronization across countries
These insights informed ongoing improvements, including clearer guidance, better contextual communication, and plans for deeper integration into core offer management flows.
Outcome
By February, the assortment on our platform was considered fully compliant. Bol was technically and operationally ready for enforcement from a legal perspective.
Beyond compliance, this project established a new foundation for handling partner-specific responsibility data within a shared marketplace model. It demonstrated how regulatory requirements can be transformed into scalable platform capabilities when addressed with the right level of strategic design thinking.