By Alexander Sapov
This article is the fourth 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.
The earlier articles can be viewed at the following links:
- ISS vs. aggregator: the strategic models shaping the travel market
- ISS vs. aggregator: why legal classification matters
- ISS vs. aggregator: the real world case study of GetTransfer
Choosing between an ISS model and an aggregator model is a foundational strategic decision for any platform-based startup in transportation (or the broader sharing economy). It’s a choice that will dictate your regulatory exposure, operational flexibility, and growth trajectory. Given the implications, we explore below the key takeaways for founders and executives to consider.
Regulatory classification is strategic
Plan your business model with legal classification in mind. If you opt for deep control (pricing, dispatch, branding of the service), be prepared for high regulatory burdens as a sector provider – you may need local licences, and compliance will be complex.
If you design as a neutral marketplace, you can leverage the Information Society Service framework to operate under a lighter, uniform regulatory regime across markets, though you’ll still enforce quality indirectly. Early consultation with legal experts on how your model will be classified in key jurisdictions is essential; a misclassification can lead to lawsuits or shutdowns.
Scalability vs. control trade-off
The aggregator model lets you control the user experience end-to-end, which can ensure consistency and potentially higher margins per trip, but it tends to scale slowly due to the need for regulatory clearance and heavy local operations. The ISS model sacrifices control (allowing drivers and market forces to set terms) in exchange for fast, global scalability and lower overhead.
For companies aiming at global markets or many diverse regions, the ISS marketplace approach can be a force-multiplier – you grow by onboarding partners, not by deploying capital in each city. On the flip side, if your strategy is to dominate a few key markets with superior service (and you have the funding to navigate regulations), an aggregator approach might be viable. Align this choice with your growth strategy and resources.
Pricing model and market dynamics
Your pricing strategy is intertwined with legal status. A pricing-setting model (like Uber’s surge algorithm or fixed fares) can be great for optimising revenue and user predictability, but it pushes you toward being seen as the service provider. A free market-driven pricing model (bids or host-set prices) may yield more variability, but it reinforces the notion that you are an open marketplace.
Consider hybrid approaches carefully – even partial control over pricing could jeopardise ISS status. Many successful marketplace platforms (Airbnb, eBay, Tripadvisor, GetTransfer) show that letting the supply side set prices doesn’t hinder growth; in fact, it can drive competitive pricing and user choice, which are assets in attracting customers.
Consumer trust and protection
Whichever model you choose, invest in consumer trust mechanisms. If you lean toward ISS, you won’t be legally required to provide the same level of consumer protection as a transport operator, but from a business standpoint you must ensure customers feel safe and supported. This means implementing driver vetting, insurance partnerships, robust customer support, and clear terms of service.
Trust is the currency of any platform. ISS platforms achieve it through transparency (driver profiles, ratings, upfront pricing) and reliability in matchmaking, not through direct control of the ride. Aggregators, by directly managing the service, inherently offer a form of assurance (the buck stops with the platform), but they must live up to that with concrete service guarantees and accountability.
In either case, put yourself in the user’s shoes: compliance and legal status mean nothing if the end-user experience falters.
Long-term strategic flexibility
Keep an eye on legal trends. Regulations evolve – for instance, the EU’s Digital Services Act and ongoing debates on gig-worker status may affect both ISS and aggregator models. An ISS strategy might face new requirements in the future (like greater duty to monitor transactions or ensure algorithmic transparency), while an aggregator might face labour law challenges or stricter local quotas. Build a model that can adapt.
Conclusion
Ultimately, the dichotomy of ISS vs. aggregator models in ride-booking is about where you draw the line between being a facilitator and being a service provider. Neither model is “right” for all situations – each comes with trade-offs. However, European case law has made it clear that if you can structure your platform to “remain independent of the underlying service”, you unlock a level of freedom to innovate and expand that a traditional operator might not have.
As an executive, you should make this choice deliberately, as it will influence everything – from your regulatory strategy and cost structure, to your branding and investor appeal. Because, in a sector often described as the Wild West meeting the rule of law, knowing exactly what your platform is (and isn’t) in the eyes of regulators, is half the battle won.
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.
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