A seller-account verification request can be easy to ignore.
Maybe the marketplace already verified your identity when you opened the account.
Maybe your bank information has not changed.
Maybe the email looks like another routine compliance notice.
Under the INFORM Consumers Act, however, certain verification requests are not just optional marketplace housekeeping.
Online marketplaces have legal obligations to collect, verify, and periodically update identifying information from qualifying high-volume third-party sellers. If a covered seller fails to provide the information required for the marketplace to comply, the marketplace can be required to suspend the seller’s future sales activity until the problem is resolved.
The law has been in effect since June 27, 2023, but it remains highly relevant in 2026 because verification is recurring rather than one-time. The Federal Trade Commission also brought its first INFORM Consumers Act enforcement case in September 2025, resulting in a proposed $2 million civil penalty against online marketplace Temu over alleged failures involving seller disclosures and consumer reporting mechanisms.
For marketplace sellers, the lesson is simple:
Seller verification is now an ongoing part of operating a marketplace business.
Here is how to determine whether the law affects you and what to do when a marketplace asks you to verify your account.
What Is the INFORM Consumers Act?
The full name is the Integrity, Notification, and Fairness in Online Retail Marketplaces for Consumers Act.
Congress created the law to increase transparency in online marketplaces and make it harder for stolen, counterfeit, or unsafe merchandise to be sold anonymously.
The law places most of the direct legal obligations on online marketplaces.
Those marketplaces must identify certain high-volume third-party sellers, collect and verify information about them, keep that information current, disclose certain seller information to consumers when required, and provide a way for shoppers to report suspicious marketplace activity.
For sellers, those marketplace obligations translate into very practical requirements.
You may be asked to provide:
Banking information
Tax identification information
Contact information
Government-issued identification or business documentation
And once you provide it, you may be required to periodically certify that the information remains accurate.
Who Counts as a High-Volume Third-Party Seller?
This is the threshold most sellers need to understand.
Under FTC guidance, a high-volume third-party seller generally is a seller that, on a particular online marketplace, has had:
200 or more separate sales or transactions
and
$5,000 or more in gross revenue
during any continuous 12-month period within the previous 24 months.
The transactions must involve new or unused consumer products, and only qualifying sales made through that marketplace for which the marketplace or its payment processor handled payment count toward the threshold.
Both parts of the threshold matter.
Practical Threshold Examples
| Seller Activity on One Marketplace | High-Volume Threshold Met? |
|---|---|
| 250 transactions and $8,000 gross revenue | Yes |
| 250 transactions and $4,500 gross revenue | No, dollar threshold not met |
| 150 transactions and $14,000 gross revenue | No, transaction threshold not met |
| 215 transactions and $5,050 gross revenue | Yes |
| 190 transactions and $4,900 gross revenue | No |
Crossing only one threshold is not enough under the statutory definition.
The Threshold Is Calculated Per Marketplace
Suppose you sell on two separate online marketplaces.
On Marketplace A you have:
120 transactions
$4,000 gross revenue
On Marketplace B you have:
130 transactions
$4,500 gross revenue
Combined, you have:
250 transactions
$8,500 revenue
But the INFORM threshold is evaluated based on the qualifying activity on a given marketplace, not by combining unrelated marketplace accounts.
FTC guidance specifically explains that the sales and gross revenue used for determining the threshold are those processed through the particular online marketplace.
So in this example, you would not automatically meet the statutory high-volume threshold on either platform solely because your combined business exceeds it.
That does not mean the marketplaces cannot ask for verification anyway.
The FTC notes that marketplaces may adopt verification practices that go beyond the minimum requirements of the INFORM Consumers Act. The law establishes a floor, not a ceiling.
What Products Count?
The law focuses on new or unused consumer products.
The underlying definition generally covers tangible personal property normally used for personal, family, or household purposes.
That distinction can matter for resellers.
Imagine a marketplace account sells:
150 used collectibles
100 new household products
Only assuming the transactions otherwise qualify, the 100 transactions involving new products may be relevant to determining the INFORM high-volume threshold rather than automatically counting all 250 transactions.
Mixed-inventory sellers should therefore understand the type of merchandise included in their marketplace activity rather than looking only at their account’s total annual order count.
What Information Can a Marketplace Require?
Once a seller becomes a high-volume third-party seller, the marketplace generally has 10 days to collect certain information.
FTC guidance describes the principal categories this way:
| Information | What May Be Requested |
|---|---|
| Bank information | Bank account number or qualifying payment-recipient information |
| Tax information | Business tax identification number or other taxpayer identification number |
| Individual seller contact information | Name, working email address, and phone number |
| Business/entity information | Working email and phone number plus qualifying government-issued identification, tax documentation, or business records showing the business name and physical address |
| Identity documentation | Valid government-issued identification for an individual acting for an entity, depending on how the account is structured |
After the seller provides the information, the marketplace generally has another 10 days to verify it using methods capable of reliably determining that the information is valid, belongs to the seller or authorized representative, and has not been falsified or misappropriated.
For sellers, this means inconsistencies that seem minor can create significant problems.
Your business name, tax records, bank account, legal entity, seller profile, address, and government identification should match where appropriate.
Why Seller Information Gets Reverified
A common mistake is thinking:
“The marketplace verified me three years ago, so I am finished.”
The law requires marketplaces to keep covered seller information current.
At least once each year, marketplaces must require high-volume third-party sellers to electronically certify that the information previously supplied is still accurate or update anything that has changed. FTC seller guidance says covered sellers may be required to respond to those requests within 10 days.
That annual process is why a seller who has operated for years without problems can suddenly receive a new identity-verification request.
It does not necessarily mean the marketplace suspects fraud.
It may simply be part of required compliance.
What Happens If You Ignore the Verification Request?
Ignoring it can eventually stop your sales.
If a high-volume seller fails to provide required information, the marketplace must give the seller written or electronic notice of noncompliance.
If the seller still does not provide the required information within the applicable 10-day period, the marketplace must suspend future sales activity until the seller complies.
For a marketplace-based business, that makes account contact information surprisingly important.
Imagine a business has an old administrative email address that nobody checks.
The marketplace sends an annual certification request.
Nobody responds.
A second compliance notice arrives.
Nobody responds again.
The seller may discover the problem only after selling privileges are interrupted.
The operational problem was not fraud, poor customer service, or defective products.
It was an unread compliance email.
When Can Your Seller Information Be Shown to Customers?
The INFORM Consumers Act contains an additional threshold affecting disclosure.
If a high-volume third-party seller generates $20,000 or more in annual gross revenue on a particular marketplace, the marketplace generally must disclose specified identifying information about the seller to consumers.
FTC guidance says required information can include the seller’s full name, physical address, and a method that allows consumers to communicate directly with the seller. The information may appear on product listings or through order-confirmation and transaction-history mechanisms allowed by the Act.
This $20,000 figure serves a different purpose from the $5,000 high-volume threshold.
Think of the two thresholds this way:
| Threshold | General Effect |
|---|---|
| 200 transactions + $5,000 gross revenue | Can make the seller a high-volume third-party seller subject to marketplace collection and verification requirements |
| $20,000 annual gross revenue for a high-volume seller | Can trigger additional consumer-facing seller disclosure requirements |
Confusing the two thresholds can cause unnecessary concern.
Crossing $5,000 does not automatically mean your home street address will suddenly appear publicly on every listing.
What If You Run the Business From Your Home?
The law contains a limited accommodation for certain high-volume sellers operating only from a personal residence.
A qualifying home-based seller can request limited treatment of the physical address disclosure.
In that situation, the marketplace may disclose the seller’s country and, when applicable, state rather than the complete home street address while still providing consumers with a way to contact the seller directly. If the only phone number is personal, another electronic contact method can be used under the circumstances described by the FTC.
There is an important tradeoff.
FTC guidance says sellers relying on the limited home-address exception must respond to consumer inquiries within a reasonable time frame to continue qualifying for that protection.
A home-based reseller therefore should not assume that requesting address privacy eliminates customer-contact responsibilities.
A Marketplace May Ask for More Than the Law Requires
Suppose you have only 80 transactions.
A marketplace nevertheless asks you to upload identity documents.
Is the marketplace necessarily violating the law?
No.
The FTC explicitly explains that marketplaces may implement collection, verification, and disclosure procedures that go beyond what the INFORM Consumers Act minimally requires.
Marketplaces have other reasons for verifying sellers, including fraud prevention, payment compliance, tax reporting, account security, product-safety programs, and their own terms of service.
So this argument usually will not help:
“I have fewer than 200 orders, therefore you aren’t allowed to verify me.”
The INFORM threshold determines when certain obligations become mandatory under that particular federal law.
It does not generally prohibit voluntary or separately required verification.
A Practical Example for a Growing Reseller
Consider an online reseller who begins the year with a small account.
During the first six months:
Gross sales: $3,100
Transactions: 130
The seller is below the INFORM high-volume threshold.
Four months later:
Gross sales over the relevant qualifying period: $6,400
Transactions: 225
Now both qualifying thresholds have been crossed.
The marketplace may need to collect and verify the seller’s required information.
Later in the year, the seller’s annual gross revenue on the platform reaches:
$24,000
The seller now may also fall within the additional disclosure requirements applicable to qualifying high-volume sellers reaching $20,000 in annual gross marketplace revenue.
Nothing unusual happened to the seller’s business.
The business simply grew.
That is exactly why verification requirements often appear suddenly for successful accounts.
Selling on Multiple Platforms Creates an Administrative Problem
The law may be applied separately across marketplaces, but your underlying identity information needs to remain consistent.
Imagine one platform has:
ABC Resale LLC
while another says:
ABC Resales
Your business bank account says:
ABC Resale LLC
Your EIN documentation also says:
ABC Resale LLC
Your driver’s license still contains an old residential address.
Your marketplace profile contains your new address.
Each discrepancy may be explainable.
Together, they can slow automated verification.
The practical solution is to maintain a small seller-compliance file containing current versions of the documents commonly requested.
A useful internal record might look like this:
| Record | Review |
|---|---|
| Legal business name | Confirm exact spelling |
| EIN / taxpayer information | Confirm current entity |
| Business address | Confirm current address |
| Bank account | Confirm ownership and account details |
| Administrative email | Confirm monitored inbox |
| Business phone | Confirm active number |
| Government ID | Confirm current and unexpired |
| Marketplace profile | Confirm it matches legal records |
| Business registration | Keep current copy |
| Verification date | Record when last completed |
Reviewing this information periodically can turn an urgent verification request into a five-minute administrative task.
Be Careful With Verification Phishing
The information marketplaces collect under the Act is exactly the kind of information criminals want:
bank account details
taxpayer information
business identity records
government identification
contact details
That creates an obvious phishing opportunity.
FTC guidance specifically warns sellers about messages from people claiming they need account information for INFORM Consumers Act compliance.
The agency recommends verifying that the request actually came from the marketplace before providing sensitive information.
A safer approach is to avoid using unexpected email links for sensitive verification.
Instead, open the marketplace through the website or app you normally use and check the account’s verification or compliance center directly.
If a request appears only in an email but not inside your legitimate seller account, verify it through a trusted marketplace support channel before sending documents.
What Sellers Should Do Before They Reach the Threshold
Waiting until a marketplace gives you 10 days is unnecessary.
A seller approaching 200 marketplace transactions should prepare in advance.
The most important goal is consistency.
If you operate through an LLC, use the legal entity consistently where the platform requires it.
If you move, update relevant records.
If a government identification document expires, renew it before a marketplace unexpectedly asks for it.
If you replace the bank account receiving marketplace deposits, verify the new account information.
And if the email address attached to the seller account belongs to an employee who left six months ago, fix that immediately.
Verification becomes difficult when the seller first has to determine what information the marketplace already has.
Don’t Confuse INFORM Verification With Tax Reporting
The INFORM Consumers Act and Form 1099-K rules are different systems.
A marketplace may have seller-verification obligations under INFORM while separately having payment-reporting obligations under tax law.
The thresholds are not interchangeable.
For example, the INFORM high-volume definition generally begins with qualifying activity of at least 200 transactions and $5,000 in gross revenue during the relevant period.
That does not mean $5,000 is a tax threshold.
It is simply part of determining whether the seller falls within the INFORM Act’s high-volume classification.
Keeping legal-compliance thresholds separate from tax thresholds prevents a great deal of confusion.
Used-Goods Sellers Should Still Pay Attention
Because the statutory definition focuses on new or unused consumer products, a business selling exclusively secondhand merchandise may have a different INFORM analysis than a conventional retailer.
But that does not mean used-goods sellers can ignore seller verification entirely.
A marketplace can impose broader identity requirements than the Act’s minimum requirements.
Additionally, many resellers sell mixed inventory.
A store might primarily sell used collectibles while also selling:
new accessories
sealed replacement parts
unused clothing
new household merchandise
If you operate a mixed catalog, do not assume your business falls completely outside the law merely because most inventory is used.
What About Business Sellers That Already Publicly Identify Themselves?
The statute includes a narrower exemption for certain businesses that satisfy multiple requirements involving their relationship with the marketplace, public availability of their identifying information, and marketplace verification.
FTC guidance describes this as applying to qualifying businesses that have a contractual relationship with the marketplace to manufacture, distribute, wholesale, or fulfill consumer products, have made their business identity and contact information publicly available, and provide identifying information that the marketplace verifies.
Ordinary marketplace resellers should not assume that simply having an LLC or public website automatically creates this exemption.
The conditions work together.
If the distinction materially affects your business, reviewing the statutory language or obtaining professional legal advice is more appropriate than relying on a general marketplace FAQ.
The First FTC Enforcement Case Shows the Law Is Active
The INFORM Consumers Act is no longer merely a new compliance rule waiting to be tested.
In September 2025, the FTC announced its first enforcement case under the Act against Whaleco, Inc., operator of Temu.
The FTC alleged that the marketplace failed in several areas, including providing required mechanisms for consumers to report suspicious marketplace activity and clearly disclosing required information concerning certain high-volume third-party sellers.
The proposed settlement included a $2 million civil penalty and required changes to the marketplace’s compliance practices.
The case was aimed at the marketplace rather than individual third-party sellers.
But it matters to sellers because enforcement pressure on marketplaces gives platforms a strong reason to enforce their own seller-verification workflows carefully.
The Seller’s Real Risk Is Business Interruption
For most legitimate resellers, the greatest practical risk is not an FTC agent appearing at the warehouse.
It is losing the ability to sell because a verification requirement was not completed.
A marketplace may represent:
20%
50%
or even nearly all
of a small reseller’s revenue.
A suspension lasting several days can therefore have a disproportionate impact.
Sales stop.
Advertising becomes useless.
Inventory remains idle.
Cash flow slows.
Customer communication becomes more complicated.
The preventative work is relatively simple: keep business records current and respond promptly when a legitimate marketplace requests verification.
2026 Seller Compliance Checklist
| Check | Recommended Action |
|---|---|
| Marketplace transaction count | Know when you are approaching 200 qualifying transactions |
| Marketplace revenue | Monitor the $5,000 high-volume threshold and $20,000 disclosure threshold separately |
| Legal business name | Match marketplace, tax, banking, and entity records where appropriate |
| Business address | Keep current across official documentation |
| Tax ID | Confirm the correct entity’s taxpayer information is on file |
| Bank account | Ensure payout account information remains accurate |
| Government ID | Keep required identification valid and unexpired |
| Seller email | Use an address someone actively monitors |
| Seller phone | Keep the number active |
| Annual certification notices | Treat legitimate verification requests as time-sensitive |
| Home-based seller status | Understand the limited address-disclosure exception if applicable |
| Phishing protection | Verify sensitive requests through the official marketplace account |
| Documentation archive | Keep a secure folder with current verification records |
Final Takeaway
The INFORM Consumers Act is not primarily a rule about paperwork.
It is a rule about marketplace identity.
Once a seller reaches the statutory high-volume threshold, marketplaces must know who is operating the account, verify specified information, keep it current, and make certain information available to consumers when additional requirements are met.
For legitimate online sellers, compliance usually is not complicated.
The difficult situations arise when:
the marketplace has outdated information,
the seller ignores a verification request,
official documents contradict one another,
or a business waits until an account is already at risk of suspension before fixing its records.
Treat seller verification as part of normal ecommerce administration.
Keep your identity, banking, tax, contact, and business records consistent.
Monitor the email address attached to your selling accounts.
And when a legitimate annual certification request arrives, do not leave it sitting in the inbox.
A few minutes of administrative work can prevent a much more expensive interruption to your business.
Sources
Federal Trade Commission — What Third Party Sellers Need to Know About the INFORM Consumers Act. Covers seller thresholds, required information, annual certification, disclosure requirements, home-based seller protections, suspension, and phishing risks.
FTC seller guide to the INFORM Consumers Act
Federal Trade Commission — Informing Businesses about the INFORM Consumers Act. Covers marketplace obligations, definitions, verification requirements, seller disclosure, and enforcement.
FTC INFORM Consumers Act business guidance
Federal Trade Commission — First INFORM Consumers Act Enforcement Case. FTC announced the first enforcement action in September 2025 and a proposed $2 million penalty.
FTC INFORM Act enforcement announcement
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