By Alexander Sapov

This article is the first in a four-part series, aiming to provide an authoritative analysis of ISS vs. aggregator models in ride-booking, and what’s at stake when choosing one over the other.

In the world of ride-booking and transfer services, not all platforms are created equal under the law.

Europe’s top court famously deemed Uber a transportation company rather than a mere digital service, whereas it affirmed that Airbnb operates as an online intermediary – an “information society service” (ISS) – not a traditional real estate firm. These legal classifications are more than labels; they determine how a platform is regulated, the responsibilities it bears, and how easily it can scale across markets.

For tech CEOs and legal professionals in the mobility sector, understanding the critical differences between an ISS model and an aggregator model is essential. Recent EU court rulings – from the 2017 Uber Spain decision to the 2019 Airbnb Ireland case and the 2020 Star Taxi App judgment – underscore how a platform’s design and operations directly affect its regulatory burden, pricing mechanisms, consumer protections, and growth trajectory.

Below, we take a deeper dive into the definitions, operational features and legal distinctions between the two models.

Defining the models

Information Society Service (ISS)

Under European Union law, an ISS is a service delivered electronically that connects buyers and sellers, without itself providing the underlying service. In practical terms, an ISS platform acts purely as a marketplace or intermediary. It facilitates a contract between a user and an independent provider, but does not execute or take responsibility for the core service offline.

Crucially, ISS platforms don’t exert decisive control over how the underlying service is carried out. For example, the EU’s Court of Justice found that Airbnb simply connects property owners with guests and “exercises no decisive control” over the accommodation or pricing, operating as a “pure marketplace” under the ISS umbrella. Because it merely intermediates and doesn’t manage the actual rentals, Airbnb gained the legal status of an ISS – affording it greater freedom from sector-specific regulation.

Aggregator / Transport platform

In contrast, an aggregator model in ride-booking is characterised by the platform’s active orchestration of the service – blurring the line between intermediary and provider. Often referred to as ride-hailing or “platform-to-consumer” services, aggregators typically set or influence pricing, control the matching of drivers to passengers, and define service standards. The platform often presents itself as the service provider to the customer, handling everything from fare calculation to payment and sometimes even driver training.

Uber’s original model is the textbook example: the company’s app didn’t just list drivers; it heavily controlled the transaction,, fixing fares via an algorithm, and ensuring passengers could not negotiate or deal directly with drivers outside the app. EU courts, notably in the Asociación Profesional Elite Taxi v. Uber Spain case (2017), concluded that Uber’s role “forms a single, composite service” centred on transport – meaning Uber was effectively operating as a transport provider, not a mere digital intermediary. In legal terms, Uber was found to be outside the ISS category because it provided an integral part of the transport service, and thus could be regulated like a transportation company by national authorities.

It’s important to note that “aggregator” is not a formal legal term, but in this context it describes platforms (like Uber, Lyft, Bolt, or Welcome Pickups) that aggregate supply (drivers) and demand (riders) while actively managing key aspects of the service delivery. Some aggregators might market themselves as intermediaries, but if they impose standardised fares, assign drivers, or otherwise insert themselves deeply into the transaction, regulators may treat them as service operators.

For instance, Welcome Pickups – an airport transfer service – advertises as an intermediary, yet sets standard prices and assigns professional drivers, aligning its model with Uber’s controlled approach than with a neutral marketplace. In summary, the distinction between an ISS and an aggregator model comes down to the platform’s level of control and involvement in the core service: ISS platforms facilitate connections, whereas aggregators manage much of the service pipeline.

Operational and legal distinctions

Several operational and legal characteristics distinguish an ISS-model platform from an aggregator-model platform in ride-booking. Below are the key areas of difference:

Control of pricing

Perhaps the clearest differentiator is who sets the price of a ride. Aggregator platforms like Uber, Lyft and Bolt typically set or algorithmically calculate fares for each trip, leaving drivers to simply accept the rate given. The platform dictates the price and the driver’s earnings are a portion of that fixed fare. ISS-model platforms (marketplaces) like GetTransfer, on the other hand, let pricing be determined by the market dynamics directly between drivers and riders.

Drivers or transport providers independently propose their own prices, and users can choose from multiple offers, creating a competitive bidding environment. The platform does not impose a standard rate or cap. This marketplace approach means supply and demand find a natural equilibrium – drivers set fares reflecting their costs (and any local tariff rules), and passengers often get a lower price than they would under a fixed-price model. In EU case law, this element is pivotal: if the platform does not set fares or rates, it is one of the criteria for being considered a mere intermediary (ISS).

Role of service providers (drivers)

Aggregator services often blur the line on the status of drivers. Companies like Uber initially recruited large numbers of non-professional drivers to offer rides via the app. The platform may have minimal requirements for drivers (beyond background checks and a car) and does not necessarily require them to hold a professional taxi or chauffeur licence.

In contrast, an ISS-oriented travel-booking platform like GetTransfer relies on licensed carriers or professional drivers who are already in business offline and operating with full compliance to local law. The platform itself owns no vehicles and employs no drivers; it simply onboards existing transportation providers who meet certain qualifications (much as Airbnb lists existing property owners or Tripadvisor list local drivers and carriers).

This means the service providers on an ISS platform typically continue to operate under their own local licenses and regulatory compliance. They might use multiple channels to find customers (street hails, personal networks, other apps) – the ISS platform is just another source of clients, not their employer. The European courts have noted this distinction: when drivers “remain fully licensed and continue business independently offline”, and the app is just one channel for bookings, the platform’s role is that of an ISS connector, not a transport operator.

Contract and relationship structure

In an aggregator model, the user’s contract or primary relationship for the ride often lies with the platform itself. For example, riders ordering an Uber typically accept Uber’s terms of service, Ubers selects driver by its’ own algorith and decides with whom Uber will make a transportation contract  and after clients rely on Uber only for any problems during the trip. Effectively, the platform is a service provider to the customer, even if drivers are independent contractors behind the scenes.

With ISS-model platforms, the platform exchanges information only, and is not involved in price setting or driver assignments The transport contract is concluded directly between the passenger and the driver (or transport company) providing the ride. The platform facilitates the booking and payment, and other information exchange only, but the end service – the ride – is delivered by the local operator under a direct agreement with the customer.

Travel booking marketplace GetTransfer, for instance, likens its role to that of Tripadvisor or Airbnb in this regard. Once a ride request is matched and confirmed, the traveller has essentially “hired” a local carrier, and GetTransfer’s role is finished when the trip begins. This has legal implications for liability and consumer recourse. On an aggregator platform, a passenger can hold the platform accountable as the organiser of the service; on an ISS platform, the passenger-entered contract with an independent driver means any service liability (e.g. accident, service quality issues) legally rests with that driver or transport provider. The ISS platform still typically offers customer support, escrowed payments, and dispute resolution as value-added services.

Platform responsibility and control

Because aggregators assume a greater role in service delivery, they also tend to exercise more control over service quality and availability. For instance, Uber and similar apps will dispatch the nearest available driver, ensure a driver is almost always available on demand, and may deactivate drivers who fall below ratings standards. They craft a consistent experience (vehicle categories, service levels, estimated arrival times) by actively managing the network. An ISS platform operates with a lighter touch: it makes information available (driver profiles, vehicle options, prices) and facilitates secure payment.

This difference was highlighted in the CJEU’s Star Taxi App decision. The court noted that if drivers are already present in the market, and have alternative ways to find passengers (i.e. the platform isn’t their sole source of business or controls their behavior), and if those drivers manage their own prices, then the app’s activity is merely connecting supply and demand – an ISS – and “is not an integral part of the transport service” itself. In short, an aggregator is deeply involved in ensuring the ride happens in a certain way, whereas an ISS platform provides the digital venue for the ride to be arranged.

These differences in operation feed directly into how laws classify the platform, which in turn drives the regulatory and compliance implications – an area to be discussed in the second article in this series.

Alexander Sapov is co-founder and CEO of GetTransfer.com, a global travel marketplace operating under the Information Society Services (ISS) model.

GetTransfer is headquartered on the Mediterranean island of Cyprus, whose tourism sector is booming in spite of global turbulence, drawing a record of over four million visitors in 2024​. This resilience in travel demand, coupled with the country’s business-friendly climate, makes Cyprus a strategic and innovative base for a globally-scaling tech company​. Positioned at the crossroads of Europe, the Middle East and Asia – alongside a supportive ecosystem recognised as one of the EU’s fastest-growing startup hubs  – Cyprus offers both connectivity and stability. Nevertheless, while proudly headquartered on the island, GetTransfer maintains a global perspective and reach, serving travellers well beyond Cypriot shores.