Digital Services Act: Comments to HOTREC draft position paper

The Digital Services Act, which should be put forward by the European Commission by the end of 2020, is likely to shape the future of the digital platform environment and could address several key HOTREC policy requests regarding the removal of illegal online content, platform market dominance and STR regulation. HOTREC is preparing a position paper which will be used to outline our policy requests towards key EU decision makers and serve as a basis for responding to the European Commission’s public consultation on the Digital Services Act (deadline 8 September). The layout of the paper and infographics still need to be developed. HOTREC Members have been invited to provide comments and feedback to draft HOTREC position paper on the Digital Services Act see below) by Tuesday 21 July EOB. Please feel free to send back the attached draft with suggestions in ‘track changes’ or as comments directly in the document. HOTREC Draft position paper: Comments from Members received so far by the HOTREC secretariat are available here below:

• Sweden: "Visita supports the draft HOTREC position paper on the Digital Services Act."
• Malta (MBB):
• France (GNI):
• Finland (MaRa): "It is positive that the Commission wants to address the pains of the platform economy more sharply. The ideas for different regulatory and policy options seem quite mature. I think that the main remarks that affect this issue are well highlighted in the HOTREC position paper."
• Austria (WKO):
• Germany (IHA):

NB - We take note of various comments received regarding the application of the Country-of-Origin principle. While many of you consider that this principle needs to be addressed and adapted, in particular to better regulate collaborative economy and STR services, some also point out that requesting broad exemptions to this principle may have undesirable side-effects for hospitality services booked online and affect HOTREC’s capacity to shape the broader EU digital policy debate. It is indeed a highly sensitive subject. As a compromise solution, we propose to request a fine-tuning of the Country-of-Origin principle in the area of the collaborative economy (including STR and meal-sharing) in order to improve their regulatory oversight at local and national level. This is reflected in the section of the position paper entitled “Good governance to address the development of collaborative economy services” of the latest version of the position paper.