Do I need to report under DAC7?

Quick flow to check whether your platform has a DAC7 reporting obligation

1

Is it a platform?

Software (like a website or app) that connects buyers and sellers. Does it enable at least one relevant activity?

  • Sale of goods
  • Personal services
  • Rental of immovable property
  • Rental of transport
Yes
2

Does an exception apply?

If the software is used only for one of these purposes, it may be excluded (no reporting required):

  • Processing payments
  • Listing users or their interests
  • Redirecting users to another platform
  • Displaying advertisements
No
3

Is there a platform operator?

Does an entity provide the digital platform (wholly or partly) to sellers under an agreement?

Who is a seller? An individual or entity (like a seller, landlord, or service provider) using the platform for relevant activities.

Yes
4

Does the operator need to report?

If yes to 1-3 (no exceptions), check the EU connection and if the platform facilitates relevant activities in the EU.

  • Is the operator based in the EU?
  • Does the platform enable a relevant activity in an EU Member State?
  • Is there an EU link (e.g., non-EU operators facilitating EU sellers)?

Quick DAC7 implementation checklist

Concise, developer-focused steps to collect, verify and report DAC7 data.

1

Identify reportable sellers & activities

Relevant activities: sale of goods, personal services, *rental of immovable property, rental of transport.

  • Exclude: governmental entities and listed entities.
  • Exclude occasional sellers with <30 transactions AND ≤ €2,000 in the period.
  • Exclude property listings rented ≥ 2,000 times per property listing in the period (hotel scale).
2

Collect required seller fields

Collect and store per the Directive & DPI XML elements (TINs, address, name, birthdate, VAT, registration number, permanent establishment details).

  • Individuals: first/last name, DOB, primary address, TIN(s), VAT if available.
  • Entities: legal name, primary address, TIN(s), VAT, business reg. no., permanent establishment details.
  • For activities: total quarterly considerations, number of relevant activities, fees/commissions withheld.
3

Due diligence & verification (timing)

Complete due diligence procedures (DDP) by 31 Dec of the reportable period; legacy sellers get until the end of the second reportable period.

  • Use platform records + any Member State electronic TIN verification where available.
  • If data is missing/unreliable: make reasonable efforts and document steps.
  • Keep due diligence evidence for at least 5 years.
4

Notification to sellers

Inform affected sellers before reporting (copy of what you will report).

Two reminders then possible account restriction / de-registration by authorities for persistent non-compliance (Member State procedures apply).

5

Report (XML) by 31 Jan

Annual report to the competent authority in the Member State of registration/residence - submit in the official DPI/DAC7 XML format.

Use OECD DPI XML schema as canonical; validate against the XSD before upload. National portals publish guidance/XSDs you should follow.

*

Immovable property (rental) - additional requirements

  • Store each property listing's full address, land reg. no. (if available), listing ID and aggregated number of rental days.
  • Aggregate subunits per the property listing rules (owner-level aggregation matters for the 2,000 test).
  • Report number of days rented and consideration per quarter for each applicable listing.
  • Keep proof for ownership or management for high-volume listings (≥2,000 rentals).

Official Sources

✓ Verified 2025-11-04

This checklist is based on authoritative sources. Always consult the official documentation for the most current requirements.

EU Tax Info:European Commission - DAC7 Overview
EU DAC7 Directive:Council Directive (EU) 2021/514 - EUR-Lex
OECD Model Rules:OECD Model Rules for Reporting by Platform Operators (DPI)
OECD XML Schema:OECD DPI XML Schema and User Guide (XSD)
Czech Republic:Finanční správa - DAC7 Portal (Czech language)

Important: This checklist is for informational purposes only and does not constitute legal or tax advice. Always verify requirements with the official sources above and consult with qualified legal and tax professionals for your specific situation.

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