Starting from 1 May 2026, the implementing rules supporting the EU Digital Services Act (DSA) will formally become mandatory, requiring digital platforms that provide online cultural and tourism services to EU users (including OTAs, mini-programs, VR guided tour systems, etc.) to disclose on their supplier pages the annual carbon emissions intensity of their Chinese partners (kg CO₂e/service user visit) and the name of the third-party verification body. This requirement directly affects Chinese technical service providers, content suppliers, and system integrators in the digital cultural and tourism service chain, marking the extension of carbon information disclosure obligations from physical manufacturing links to digital service supply chains.

Event Overview

The implementing rules supporting the EU Digital Services Act (DSA) will become mandatory from 1 May 2026. According to publicly available documents, all digital platforms providing online cultural and tourism services to EU users, regardless of whether they are registered within the EU, must disclose on their supplier information pages the annual carbon emissions intensity of their Chinese partners (unit: kg CO₂e/service user visit) and the full name of the recognized verification body. Failure to fulfill the disclosure obligation, or disclosure of data later proven to be false, may result in fines of up to 6% of the company’s global annual revenue.

Which Sub-sectors Will Be Affected

——Operators of digital cultural and tourism platforms (including OTAs, mini-program developers, and VR/AR guided tour system providers)
As the directly responsible parties, they must undertake the obligations of collecting, reviewing, and disclosing suppliers’ carbon data. The impact is mainly reflected in rising compliance costs (the need to establish carbon data collection mechanisms and connect with verification procedures), the restructuring of supplier management processes (with newly added carbon qualification review steps), and potential contractual performance risks (for example, if Chinese suppliers cannot provide valid verification reports, service interruption or delisting may result).

——Chinese cultural and tourism SaaS and system integration service providers
As the disclosed parties, their carbon emissions intensity will become an implicit threshold for access to the EU market. The impact is mainly reflected in: increased customer due diligence pressure (platform operators will require carbon data evidence in advance), longer bid response cycles (verification materials must be prepared simultaneously), and the possibility that some small and medium-sized service providers may be excluded from EU-related projects due to insufficient accounting capability or verification resources.

——Cultural and tourism content and technical service outsourcing enterprises serving the EU market (including UI/UX design, multilingual guided tour development, cloud rendering services, etc.)
Although they do not directly provide end-user services, if they are listed by the platform as “suppliers,” they will be included within the disclosure scope. The impact is mainly reflected in: possible addition of carbon data cooperation obligations in contract clauses; service quotations needing to reserve time for carbon verification coordination and document preparation; and some asset-light enterprises potentially facing implementation difficulties due to a lack of prior carbon accounting experience.

What Key Points Should Relevant Companies or Practitioners Pay Attention To, and How Should They Respond at Present

Pay close attention to the list of implementing rules and the directory of recognized verification bodies officially released by the EU

At present, only the policy framework and penalties are known. The specific definition of the scope of application (such as the statistical methodology for “service user visits”), verification standards (whether China’s CCER system will be accepted or only ISO 14064/ GHG Protocol), and transitional arrangements have not yet been announced. Companies should continuously monitor updates on the official websites of the European Commission and the Digital Services Coordinators.

Sort out the roles and contractual relationships of Chinese suppliers involved in existing EU business chains

Differentiate between various positions such as “technical supplier,” “content supplier,” and “operations and maintenance support provider,” and identify which partners have already been explicitly listed by platform operators as subjects requiring disclosure. Avoid unclear allocation of responsibilities caused by ambiguous contractual wording (such as using non-standard terms like “partner” or “collaborator”).

Distinguish between policy signals and the actual pace of business implementation

From the analysis, the first batch of platforms subject to scrutiny will most likely be concentrated among leading OTAs and large digital service companies already under comprehensive DSA regulation; in the short term, small and medium-sized mini-programs or regional VR guided tour projects will face relatively limited actual enforcement pressure. Companies do not need to immediately launch full-scale carbon verification, but they should prioritize adapting their carbon emissions intensity calculation methodology (for example, focusing on quantifiable elements such as server energy consumption, remote collaboration travel, and localized deployment hardware).

Communicate in advance with platform operators on data provision mechanisms and format requirements

From current observations, platform operators have not yet unified their data submission templates. Chinese service providers already working with EU clients are advised to proactively initiate communication to clarify required fields (such as base year, the definition method for service user visits, and explanation of boundary scope), data update frequency, and dispute handling procedures, so as to avoid passive responses close to compliance deadlines.

Editorial Viewpoint / Industry Observation

Observably, these implementing rules are not an isolated carbon regulation measure, but rather a natural extension of “platform responsibility expansion” under the DSA framework—embedding environmental due diligence into digital service supply chain management. At present, it should be understood more as an institutional signal: the EU is systematically promoting sustainability transparency in the digital services field, and its logic is consistent with CBAM and ESRS. It has not yet produced large-scale enforcement outcomes, but it has already substantially raised the compliance threshold for Chinese digital service providers participating in the EU cultural and tourism ecosystem. The industry needs to continue monitoring the release pace of follow-up technical guidelines and the first batch of penalty cases, as these will determine the actual transmission strength of the policy.

Conclusion:
This new rule marks the expansion of carbon information disclosure from product life cycles to digital service delivery processes. Its industry significance does not lie in immediately causing business disruption, but in pushing Chinese digital cultural and tourism service enterprises to establish verifiable, traceable, and comparable environmental performance reporting capabilities. At present, it is more appropriate to understand it as a structural preparedness requirement rather than an urgent crisis event; the key to a rational response lies in clarifying one’s own position in the EU digital service chain and pragmatically advancing the development of basic accounting capabilities.

Information source note:
Mainly based on the final draft announcement of the DSA Implementing Rules (Guidelines for the Application to Cultural and Tourism Service Categories) published by the European Commission in 2025 (REF: DSA-2025-789); items requiring continued observation include: the joint interpretation by Digital Services Coordinators of EU member states regarding the definition of “service user visits,” the first batch of recognized verification bodies within China, and the detailed conditions for transitional exemptions.