Editor's Note: On January 23, 2026, the Management Measures for Online Freight Carrier Platform Operations (Transport Regulation [2026] No. 1, hereinafter referred to as the "New Measures") officially came into effect. Compared to the Interim Measures for the Administration of Online Platform Road Freight Transport Operations issued in 2019 (hereinafter referred to as the "Interim Measures"), the New Measures align with the trends of digitalized tax supervision and the construction of a unified national market. They also connect with regulations already implemented in 2025, such as the Provisions on the Reporting of Tax-Related Information by Internet Platform Enterprises (hereinafter referred to as the "Tax Information Reporting Provisions"), collectively establishing a stricter regulatory framework. The New Measures focus on addressing long-standing industry pain points like fraudulent invoicing and non-genuine business by clarifying platform responsibilities, strengthening data sharing, and enabling full-process business traceability. This article will analyze specific changes and impacts by comparing old and new clauses and provide compliance operation recommendations for platforms.

I. Clarification of Regulatory Scope: Distinguishing "Carrier Platforms" from "Matching Platforms"

The New Measures introduce new institutional arrangements for the regulation of "online freight matching platforms." This adjustment further clarifies the applicable boundaries of the management measures, reflecting a categorized regulatory approach.

This revision signifies a refinement in regulatory thinking. The change lies in moving from the simple exclusion of "information matching services" from the constraints of clauses in the 2019 Interim Measures to their recognition in the New Measures as a business model requiring separate and specialized regulation. The essence of this adjustment is that "carrier platforms" and "matching platforms" differ in their business models, legal responsibilities, and core risks:

(1) Different Legal Status and Responsibilities

An "online freight carrier platform," as the carrier of transport services, must directly enter into transport contracts with consignors and assume responsibility for the entire transport process. This legal positioning determines that its tax treatment revolves around the entire transport service chain, with risk points concentrated on the authenticity of business and compliance of input tax deductions.

(2) Different Nature of Income and Regulatory Focus

An "online freight matching platform" is essentially an information intermediary or broker, with its primary income sources being information service fees and commissions. Therefore, the regulatory focus leans more towards the authenticity of matched transactions, the compliance of the platform's own income, the fulfillment of information reporting obligations under the 2025 Tax Information Reporting Provisions, and the risk of facilitating illegal activities such as fraudulent invoicing or money laundering.

It must be emphasized that separately listing the regulatory requirements for "matching platforms" and specifying that they are "subject to separate provisions" does not grant them regulatory exemption. Rather, it means they will be subject to a set of specialized rules matching their intermediary nature. For enterprises, the primary task is to accurately position their own business model (carrier or matching), thereby clarifying the corresponding regulatory model and avoiding compliance risks arising from role confusion. Relevant enterprises must also closely monitor future specialized regulatory provisions for matching platforms.

II. Tax Management Responsibilities: Scope Expansion and Obligation Specification

The revisions in the tax management section of the New Measures focus on integrating, clarifying, and emphasizing the various platform-related obligations and responsibilities scattered across tax laws and regulations, making them more prominent and specific within the context of online freight industry regulation, and guiding platforms to build a comprehensive tax compliance management system.

(1) Integrating and Emphasizing Compliance Obligations for All Tax Types

Article 19 of the New Measures explicitly expands the prohibition scope from emphasizing "fraudulently issuing or falsely offsetting Value-Added Tax (VAT) invoices" in the Interim Measures to "fraudulently issuing invoices, fraudulently offsetting VAT input tax, and fraudulently deducting enterprise income tax expenses." This change does not create new tax law obligations but integrates and consolidates the expression of existing requirements under the Enterprise Income Tax Law and its implementation regulations regarding the authenticity and legality of pre-tax deductions with the relevant VAT prohibitions. This alerts platforms to focus on comprehensive tax compliance under their business models, especially ensuring the authenticity and documentary compliance of all cost and expense claims. Financial systems need the capability to support precise matching and verification of costs with specific waybills.

(2) Specifying Platform Tax-Related Assistance Obligations

The newly added clause on "obligations to handle tax declaration and payment on behalf" in Article 20 of the New Measures derives its legal basis from the Tax Collection and Administration Law and the 2025 Tax Information Reporting Provisions, among others. The role of this clause is to explicitly cite and emphasize the potential assistance obligations platforms may bear, such as tax withholding or collection on behalf, within this industry-specific management measure. This makes the platform's tax-related roles and responsibilities clearer. Platforms must assess and fulfill their tax-related assistance and management responsibilities towards actual carriers on the platform based on relevant tax laws and regulations, and build supporting systems and processes.

(3) Reiterating Legal Consequences for Illegal Acts

Article 24 of the New Measures, while clarifying that tax authorities will handle cases according to law, adds the statement "if suspected of constituting a crime, [the case] shall be transferred to judicial authorities according to law." This provision is a connecting reiteration of relevant clauses in the Tax Collection and Administration Law and the Criminal Law. Its significance lies in explicitly warning of the serious consequences of tax-related illegal and criminal acts at the level of industry management measures, reminding platforms to prioritize compliance management to prevent major risks that could lead to administrative or even criminal liability.

III. Regulatory Coordination Mechanism: Institutionalizing Data Sharing and Cross-Departmental Verification

The revisions regarding regulatory coordination in the New Measures aim to establish a more efficient and close cross-departmental linkage mechanism. Its impact extends not only to online freight platforms themselves but also to a large number of upstream and downstream industries relying on road transport.

(1) Establishing Systematic and Automated Data Sharing Channels

The method of data interaction is explicitly upgraded from "timely transmission" in the Interim Measures (often relying on offline or non-standardized interfaces) to sharing via the "National Integrated Government Big Data System." This means that business data from the transport department—such as waybills, real-time vehicle trajectories, and driver identity—will achieve regularized automatic comparison and interaction with data from the tax department, such as invoice issuance, tax declarations, and corporate fund flows, breaking down data barriers between departments.

(2) Forming an Institutionalized Cross-Departmental Joint Verification Process

For the first time, the New Measures establish, in a dedicated article, a "regularized consultation mechanism" between transport and tax authorities and clarify the collaborative process of "tax authorities transferring cases to transport authorities for review, with results fed back to tax authorities." This marks the official shift from independent departmental supervision to coordinated supervision for freight-related business oversight, forming a cross-professional regulatory closed loop.

The impact of this mechanism is not limited to online freight platforms themselves; it will also directly affect industries with high levels of road transport participation, such as renewable resource recycling, coal, building materials, and bulk commodity trade. For traders or production enterprises (i.e., consignors) within these industries, even if not directly subject to the New Measures, the logistics data corresponding to their business (recorded by freight platforms) have been incorporated into the regulatory scope. When tax authorities verify the authenticity of related business and have doubts about the fund flow or invoice flow of a transaction, they can leverage this coordination mechanism to take the following measures: First, proactively retrieve transport data for verification, using the system to query whether there are matching waybills and trajectories within the corresponding period to verify if goods were actually moved. Second, initiate joint verification, transferring the points of suspicion to the transport department to verify the qualifications of carrier vehicles, the reasonableness of transport routes, etc., to determine the authenticity of the business.

IV. Business Authenticity Control: Full-Process Information Traceability Required for Fuel Invoice Deductions

The New Measures refine the rules for information recording regarding platforms' self-procurement of fuel and payment of toll fees. This revision needs to be understood in conjunction with relevant tax policies. Its intent is to ensure that special tax policies are implemented under strict supervision to prevent policy abuse.

(1) Policy Background of the New Clause

The Announcement of the State Taxation Administration on VAT Issues Such as Tax Exemption Filing for Cross-Border Taxable Behaviors (State Taxation Administration Announcement [2017] No. 30, hereinafter "Announcement 30") first clarified that the input tax on refined oil and toll fees purchased by online freight platforms for actual carriers is allowed for deduction. The Announcement of the Ministry of Finance and the State Taxation Administration on Clarifying VAT Policies for Express Delivery Services, etc. (Ministry of Finance and State Taxation Administration Announcement [2025] No. 5, hereinafter "Announcement 5") further expanded the deductible scope to various energy sources such as natural gas, electricity, and hydrogen. These two policies aim to address the industry pain point of insufficient platform input tax, but their effectiveness prerequisite is that the related expenditures must be genuinely used for the actual transport services commissioned by the platform. To prevent fictitious business and fraudulent invoicing to obtain deductions, the New Measures added the aforementioned clauses, aiming to ensure tax policies are not abused by refining information recording requirements and clarifying the retention of evidence linking invoices to actual business consumption.

(2) Comparison, Purpose, and Reasons for 2025 and 2026 Clauses:

Compared to the 2025 "Draft for Comments," the wording of the 2026 New Measures has been slightly adjusted to make requirements clearer and more focused:

• From "Fuel (Energy)" to "Fuel": Article 18 of the New Measures simplifies "fuel (energy)" to "fuel". This adjustment does not narrow the scope but aligns the clause's wording with the legislative technique of the 2025 Announcement 5. Announcement 5, when clarifying the deductible scope, used the enumeration method: "refined oil, natural gas, electricity, hydrogen, dimethyl ether, methanol, and other various vehicle fuels (energy)." The New Measures use "fuel" as a general term, whose specific scope should be determined according to Announcement 5, thereby establishing a clear correspondence between regulatory requirements and substantive tax policies.
• From "Toll Fee Payment and Other Information" to "Vehicle Toll Fee Information": Changing "toll fee payment and other information" to "vehicle toll fee information" emphasizes that the key information is the toll fee details linked to specific transport vehicles, not just payment vouchers. This requires the information recorded by platforms to be directly associated with specific vehicles and transport tasks, enhancing the information's relevance and verification value.

(3) Interpretation and Impact Analysis

1. Establishing a Strongly Linked Evidence Chain of "Invoice - Business - Vehicle"

The new rules requiring the recording of "procurement, delivery, use, recovery" full-process information aim to lock a fuel or toll invoice to the following elements through data: procurement source, allocation target (specific vehicle/driver), and consumption scenario (specific waybill and travel trajectory). This enables tax authorities to pierce through the invoice form and verify the business substance of the deduction item, i.e., whether the related expenditure actually occurred and was used for the platform's transport business.

2. Setting Clear Requirements for Platform Operation Models and Technical Capabilities

This provision constrains two common but non-standard practices: First, the model where platforms "centrally procure fuel cards and centrally deduct invoices" but cannot perform downstream allocation verification. Second, cooperation with third-party "fueling platforms" where only invoices are obtained without access to real, detailed fueling data streams. Compliant operations require platforms to use technological means to achieve real-time, precise matching and association of waybills, vehicle trajectories, and fueling/toll payment records. This essentially internalizes compliance capability as part of the platform's core operational capability. Platforms lacking corresponding data governance capabilities will face ongoing tax risks.

V. Summary

Overall, the changes in the 2026 Management Measures for Online Freight Carrier Platform Operations are reflected in two aspects: First, strengthening cross-departmental coordinated supervision through institutionalized data sharing. Second, ensuring the authenticity of input tax deductions by requiring the recording of full-process business information. For online freight platforms, the new regulations mean expanded and specified compliance responsibilities. Platforms need to shift from a past focus mainly on the invoicing link to establishing comprehensive compliance management covering tax treatment, data reporting, and business authenticity verification. Their role needs to transform from providing documents and information services to becoming a responsible operating entity capable of ensuring that transport contracts, waybills, trajectories, fund flows, and invoices match and are verifiable. In this context, compliance capability has become an indispensable foundation for stable platform operation. Only platforms that meet the stipulated requirements in actual business, data management, and internal controls can achieve long-term development in the increasingly standardized regulatory environment.