Effective from 5/1/2026, the implementing rules supporting the EU Digital Services Act (DSA) will officially take effect, requiring cultural and tourism digital platforms operating for European users (including OTAs, smart guide Apps, VR scenic area platforms, etc.) to disclose the Scope 1+2 carbon emissions data of their Chinese suppliers and third-party verification statements. This policy directly affects the export compliance pathways to Europe for Chinese cultural and tourism SaaS companies, smart hardware manufacturers, and system integrators. Those that fail to meet the requirements may face the risk of platform delisting and procurement rejection, so enterprises related to the cultural and tourism digital service supply chain need to pay close attention.

Event Overview

According to publicly available information, from 5/1/2026, the implementing rules supporting the EU Digital Services Act (DSA) will be formally implemented. The rules make it clear that all cultural and tourism digital platforms providing services to end users within the EU (including online travel platforms (OTAs), mobile smart guide applications, virtual reality (VR) scenic area service platforms, etc.) must prominently disclose on their platforms the Scope 1 (direct emissions) and Scope 2 (indirect emissions generated from purchased electricity, steam, cooling, and heating) carbon emissions data of the Chinese suppliers they work with, and simultaneously publish verification statements issued by recognized third-party institutions. This requirement does not apply retroactively and only applies to newly signed or renewed supplier cooperation relationships after the new rules take effect.

Which Sub-Sectors Will Be Affected

— Cultural and Tourism SaaS Service Enterprises
As they are directly included in the supplier list as platform technology service providers or system delivery parties, their own operational carbon emissions (such as data center electricity use and office site energy consumption) will be collected and disclosed by the platform side. The impact is mainly reflected in: the addition of carbon data reporting obligation clauses in customer contracts; some European platforms may incorporate carbon performance into access evaluation indicators; enterprises that have not established a carbon accounting system face the risk of missing data.

— Smart Hardware Manufacturers (including scenic area IoT devices, AR/VR terminals, self-service guide machines, etc.)
As a core link in the hardware supply chain of cultural and tourism platforms, their production and manufacturing processes (factory electricity use, fuel consumption) fall within Scope 1+2. The impact is mainly reflected in: the need to provide the platform side with production-line-level or factory-level carbon emissions reports; if contract manufacturers are not covered by carbon inventorying, the finished-device manufacturer will need to assume data traceability responsibility; export orders may be temporarily suspended from access or delisted due to incomplete carbon data.

— System Integrators (including prime contractors for smart scenic areas and implementers of digital twin projects)
They usually integrate multi-source software and hardware and constitute a “composite supplier” in project delivery. The impact is mainly reflected in: the need to clarify the attribution of carbon responsibility within their own service boundaries (for example, whether cloud resource usage is counted in Scope 2); increased difficulty in cross-vendor data coordination; some European cultural and tourism platforms may require the overall integration solution to pass carbon compliance certification.

What Key Points Should Relevant Enterprises or Practitioners Focus On, and How Should They Respond at Present

Pay attention to the follow-up implementation guidelines issued officially by the EU and the list of recognized verification institutions

At present, only the disclosure obligation framework has been clarified, while the qualification recognition standards for third-party verification institutions, data template formats, and exemption scenarios have not yet been announced. Enterprises should continue to follow updates on the official websites of the European Commission and the European Environment Agency (EEA) to avoid interpreting and implementing based on non-authoritative channels.

Prioritize sorting out the existing partner platform list and contract performance milestones for the EU market

Identify which platforms have already carried out DSA compliance upgrades, which are in a transition period, and which have not yet started; focus on cooperation agreements that will be renewed or newly added after 5/2026, and incorporate carbon data clauses into the coordinated review process of legal and procurement teams.

Distinguish policy signals from the actual pace of business implementation

Based on the analysis, the first batch of implementing entities is highly likely to be concentrated among leading OTA platforms (such as Booking.com and GetYourGuide) and contractors for EU public cultural and tourism digitalization projects; small and medium-sized platforms may have a buffer period of 6–12 months. Enterprises do not need to immediately launch a full-scale carbon inventory across the board, but they should establish preliminary Scope 1+2 measurement capabilities for core product lines/main factories.

Start internal foundational preparations for carbon data management in advance

Including: clarifying the responsible department for energy ledgers (such as administration/IT/production); unifying the units of measurement and statistical cycles for electricity, gas, oil, and other energy sources; conducting pre-assessments with 1–2 domestic verification institutions qualified under ISO 14064-1; establishing a response mechanism for external disclosure of carbon data (such as legal review, version retention, and update frequency settings).

Editorial Viewpoint / Industry Observation

Observably, this requirement is not an isolated carbon regulation, but a concretization in the sustainability dimension of the “extension of platform responsibility” logic under the DSA framework. At present, it should be understood more as a structural compliance signal—it marks that the EU is gradually incorporating the environmental performance of digital service supply chains from the stage of voluntary ESG reporting into mandatory market access conditions. From an industry perspective, the intensity of its implementation depends on the willingness of platforms to enforce it and the frequency of regulatory spot checks. In the short term, it may not necessarily lead to large-scale delisting, but it has already substantially raised the compliance cost threshold for Chinese cultural and tourism technology enterprises serving Europe. The industry needs to continue paying attention to the first batch of platform disclosure samples from the second quarter of 2026 and the enforcement trends of EU Digital Services Coordinators (DSC).

Conclusion:
This new regulation is not a one-time compliance check, but an institutional redefinition of the carbon responsibility interface in the globalization process of cultural and tourism digital services. Its significance lies not in immediate elimination, but in forcing Chinese enterprises to move carbon management from a back-office support function to a necessary component of product delivery and customer cooperation. At present, it is more appropriate to understand it as a “progressive compliance starting point” rather than an insurmountable market access barrier.

Information Source Note:
Mainly based on the Detailed Implementing Rules of the DSA on Environmental Information Disclosure for Cultural and Tourism Digital Platforms (document number: COM(2025) 189 final) issued by the European Commission in 2025 and the supporting Q&A summary. Areas requiring continued observation include: the specific enforcement scale of Digital Services Coordinators (DSC) in each member state, progress in cross-border recognition of third-party verification institutions, and detailed rules for exemption scenarios.