By Alexander Sapov

This article is the third 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.

Read the previous articles at the links below:

Earlier in this series, we covered how an aggregator model faces a heavier regulatory load and direct accountability for the service, while an ISS model enjoys a lighter regulatory touch. Below, we explore the implications of this distinction, through the lens of GetTransfer.com – a real-world case study of the ISS model in action.

Scaling across 180+ markets via a marketplace model

As a global marketplace operating in 180+ countries, GetTransfer has been able to scale rapidly by leveraging the advantages of being an information society service. The platform’s approach – not owning vehicles, not employing drivers, and not setting prices – but instead connecting travelers with a network of independent transport providers – aligns with the ISS criteria established by EU case law. This design has directly supported its scalability and compliance in diverse markets.

Scalability

An ISS-platform like GetTransfer can enter new markets with far fewer hurdles than an aggregator. Since it’s essentially a tech platform that onboards local licensed carriers, it usually does not need a physical operating license as a transport company in each jurisdiction. By comparison, Uber, despite its resources, operates in around 70 countries after a decade in business, often having to exit or fight legal battles in markets where it couldn’t easily comply with local transport rules.

GetTransfer’s marketplace model means each independent driver or transport firm handles compliance with their local transport laws – they must have whatever permits or insurance their jurisdiction requires to offer rides. The platform serves as a conduit for their services, much like a travel website that lists third-party tours globally. This distributed compliance model scales elegantly: as long as each provider is legit locally, the platform can expand without a tangle of regulatory approvals. Indeed, EU courts have noted that when drivers/providers are already lawfully operating in the market (just finding customers via the app), the platform is not forming a new transport service – it’s extending the reach of existing services via the internet and information exchange.

Consistency vs. flexibility

Operating as an ISS has allowed GetTransfer to maintain consistency in its user experience while respecting local differences. Travellers use the same app/interface worldwide, get upfront quotes in their currency, and enjoy standard features (like secure online payment and multilingual support) no matter the country.

Meanwhile, because pricing is market-driven and providers bid for rides, the system adapts to local economic conditions automatically – in a high-cost city, bids will reflect those costs; in a smaller town, prices may be lower. The platform doesn’t impose one-size-fits-all rates, which could clash with local regulations or norms. Providers on GetTransfer can factor in legal tariff obligations (e.g. if a city has a minimum fare rule for airport transfers) when they bid, ensuring compliance is baked into the marketplace. This flexibility has been pivotal for compliance across 180+ markets, as the platform can accommodate local rules through its providers rather than fighting against them.

Regulatory compliance

GetTransfer’s ISS status does not mean it ignores regulation – rather, it complies in a different way. The company invests in vetting drivers and carriers , sets terms of use that require service quality and legal compliance from providers, and follows all EU-wide directives . By “staying out of price-setting, vehicle management, and regulatory requirements typically associated with the transport sector”, GetTransfer keeps itself within the lawful definition of an intermediary.

This positions the platform to claim the protections of the ISS classification if challenged. In jurisdictions with specific rules for ride intermediaries, GetTransfer can usually meet those by demonstrating that drivers using the platform are licensed, and that the platform itself is just facilitating contact and payment. Essentially, compliance is managed through platform policies and partner requirements, rather than direct licensing of the platform as a transport operator. This approach has allowed GetTransfer to navigate a complex mosaic of 180+ legal environments with relatively lean overhead.

The ISS model also influences the business’s economics: GetTransfer as a marketplace takes a commission on each booking rather than setting the price and taking the remainder. While this can mean thinner margins per trip compared to an aggregator that dynamically prices rides, the trade-off comes in dramatically lower operational costs (no driver salaries or vehicle costs) and the ability to access a truly global customer base. In the long run, the marketplace model scales by volume and network effects – more drivers attract more customers and vice versa – without being bottlenecked by regulatory approvals or fleet expansion. This is how GetTransfer could process over 2,000,000 rides across continents, positioning itself as a global travel marketplace rather than a city-by-city taxi service.

For tech CEOs eyeing international growth, GetTransfer’s experience underscores that choosing an ISS platform strategy can unlock scalability that an aggregator might struggle to achieve under heavy local regulation. But the decision must align with the company’s ability to maintain service quality via indirect means (ratings, competition, incentives), rather than the direct oversight an aggregator wields.

In the final article in this series, we will explore the strategic takeaways of this ISS vs. aggregator model deep-dive for platform founders.

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.