DAC7 reporting: what platforms and sellers need to know

An email arrives from the marketplace you sell on. It wants your tax identification number, your date of birth and your business registration number, and it warns that your payouts stop in 60 days if you do not supply them. Nothing about the way you sell has changed. Nobody has explained why any of this is suddenly required.

DAC7 is the reason. It is an EU rule that obliges digital platforms to hand tax authorities detailed information about the people selling through them, and it has been reshaping marketplace onboarding since 2023.

This post covers both sides of that relationship: what platform operators have to report, and what the reporting means for the sellers whose data goes into the file. It starts by separating DAC7 from the regimes it gets confused with, because most of what you need to know depends on knowing which rule you are dealing with.

What is DAC7?

DAC7 is the seventh amendment to the EU's Directive on Administrative Cooperation. It requires digital platforms to collect information about their sellers and report it to a national tax authority once a year, covering who those sellers are and how much they earned.

Understand first what DAC7 is not.

What it changes is visibility. Platform income was largely invisible to national tax authorities, and a tax office had no practical way of knowing that one of its residents earned steadily through a marketplace incorporated somewhere else.

DAC7 closes that gap by making the platform the reporting point, then circulating the results. Information reported in one member state is exchanged automatically with the others, so a seller's home tax authority receives their figures whichever platform reported them. The directive entered into force on 1 January 2023, and authorities first exchanged information at the end of February 2024.

DAC7 vs CESOP, marketplace VAT rules and ViDA

DAC7 arrived alongside three other EU reporting reforms, and platforms routinely mistake one for another. The distinction that matters most is simple: DAC7 reports who earned what. The others govern who collects tax on what.

Regime	Who reports	What is reported	Creates a tax liability?
DAC7	Platform operators	Seller identity and income, per quarter	No. Disclosure only
CESOP	Payment service providers	Cross-border payment data	No. Disclosure only
Marketplace facilitator rules	Platforms, as deemed supplier	Nothing separate. The platform charges VAT	Yes. The platform collects and remits
ViDA digital reporting	Businesses making supplies	Transaction-level VAT data via e-invoicing	No new liability, new reporting mechanics

A platform can sit inside three of these at once, with separate reporting obligations that share almost no data.

• If you process your own payments, CESOP may catch you as well.
• Marketplace facilitator rules go further than any of them, making the platform liable for the VAT itself.
• The digital reporting requirements arriving with ViDA run on their own timetable.

Who has to report under DAC7?

Reporting obligations sit on the platform operator, always. Sellers supply information when asked, but they never file anything themselves, and no amount of seller cooperation transfers the duty.

"Platform" is defined broadly. It covers any software that allows sellers to connect with users to carry out a relevant activity, which catches many businesses that would not describe themselves as marketplaces. Being small does not exempt you, and neither does calling yourself something else.

Union and non-union platform operators

Union platform operators are resident in an EU member state, incorporated there, managed from there, or have a permanent establishment there.

Non-union operators are in scope too. A platform based anywhere falls under DAC7 when it facilitates relevant activities for EU-resident sellers, or the rental of property located in the EU. Those operators register in a single member state and receive an individual identification number, then report everything through it. It works as a one-stop shop, so registering 27 times is not the expectation.

Two exclusions that get muddled

The first is about the software. Annex V of the directive states that "platform" does not include software that, without any further intervention in carrying out a relevant activity, exclusively allows one of the following:

• Processing payments in relation to a relevant activity
• Users to list or advertise a relevant activity
• Redirecting or transferring users to a platform

The words doing the work are "without any further intervention" and "exclusively". A classifieds site that only lists items falls outside. Add payment collection and you are back in scope.

The second is narrower and widely misunderstood. An excluded platform operator is one that has demonstrated, upfront and annually, to the satisfaction of the competent authority, that its entire business model gives it no reportable sellers. That is not a size threshold. It is a positive case you make to a tax authority every year.

Which sellers and activities are reportable?

Reportable sellers are not only the ones trading across borders. Reporting covers purely domestic transactions too, which trips up platforms that assume DAC7 is an international measure, scope their build accordingly, then discover their domestic sellers were reportable all along.

The four relevant activities

Ireland's Revenue sets out the four activities in scope:

• The sale of goods
• The rental of immovable property, such as accommodation
• The provision of personal services, meaning time-based or task-based work carried out online or offline after being facilitated through a platform
• The rental of any mode of transport

Personal services is the broadest and the most often misread. It does not require a physical service or a local one. A task performed entirely online, arranged through your platform, counts. One carve-out worth knowing: work done by a seller acting as an employee of the platform operator, or of a related entity, is not a relevant activity at all.

Sellers who are excluded

Four categories never become reportable sellers. Revenue lists them as:

• Government entities
• Listed companies
• Low-volume goods sellers
• High-volume property operators, meaning sellers for whom the platform facilitated more than 2,000 rentals against a single property listing

The threshold that applies to goods only

Here is the part the rest of the internet gets wrong. The de minimis exclusion is narrow: Annex V excludes a seller for whom the platform facilitated fewer than 30 relevant activities by means of the sale of goods, and whose total consideration did not exceed €2,000 during the period.

It applies to sellers of goods and nobody else, though several large marketplaces present it in their help pages as a general DAC7 threshold. For services, property rental and transport rental there is no floor at all:

• A landlord with two bookings is reportable.
• A consultant with one client is reportable.

Platforms in those categories cannot filter their seller base down before reporting.

What information platforms have to collect and report

Due diligence and reporting are two obligations rather than one. Platforms must determine whether what they collect is reliable, using records already in their possession plus any electronic interface a member state or the EU provides free of charge to check a TIN or VAT number. Accepting whatever a seller types into a form does not meet the standard.

The reportable information falls into three groups, set out in Sections II and III of Annex V.

Seller identity

• For individuals: first and last name, primary address, any TIN with each member state of issuance, date of birth, and VAT number where available. Where there is no TIN, the place of birth instead
• For entities: legal name, primary address, any TIN with each member state of issuance, VAT number where available, business registration number, and any permanent establishment in the EU through which relevant activities are carried out

Financial information

• Total consideration paid or credited during each quarter of the period, not as an annual total
• The number of relevant activities that consideration relates to
• Any fees, commissions or taxes the platform withheld or charged during each quarter
• The financial account identifier the money was paid into, and the account holder's name where it differs from the seller's

Property information, for rentals

• The address of each property listing
• The respective land registration number, where available
• The number of days each listing was rented, and the type of each listing, where available

Where this lives in your systems

Read that list as a data problem and the work takes shape.

Reportable data	Where it usually sits
Seller identity	Onboarding or KYC
Financial account identifier	The payments provider
Consideration and fees	Billing, though often aggregated annually rather than by quarter, which is the wrong granularity
Tax identification numbers	Typically nowhere at all

Platforms that never asked for a TIN at signup end up running a retroactive collection campaign across their whole seller base, under a deadline, with account restrictions as the only real lever. That is the email in the introduction, and almost always the consequence of a field that was never added to the signup form.

Deadlines, due diligence and penalties

Platform operators file by 31 January for the previous calendar year, in the member state where they are registered. Authorities then exchange the data with each other.

The filing date is not where the work starts. Annex V requires due diligence to be complete by 31 December of the reportable period, a month ahead of the deadline most teams have in their calendar. A platform can rely on due diligence done in earlier periods, provided the information was collected, verified or confirmed within the last 36 months and nothing suggests it has become unreliable.

Stage	Timing	Who acts
Collect and verify seller information	By 31 December of the reportable year	Platform operator
File the report	By 31 January following the year	Platform operator
Exchange between tax authorities	After filing	Member states

When a seller will not provide their data, the platform escalates on a defined schedule:

1. The initial request for the missing information.
2. Two reminders after that request.
3. No sooner than 60 days after the initial request, the platform must either close the account and prevent re-registration, or withhold payment until the information arrives.

Platforms are not being aggressive when they freeze payouts, and the 60 days in that warning email is not a number they invented.

Penalties are set by each member state rather than centrally, and the directive asks only that they be effective, proportionate and dissuasive, so they vary widely. For non-union operators the consequence is sharper: after two reminders, registration is revoked between 30 and 90 days later, and member states may coordinate to stop the platform operating in the EU.

What DAC7 means if you sell on a marketplace

For sellers, DAC7 shows up as an unexplained demand for personal data from a company you thought only needed your bank details. The platform is legally required to hold your tax identification number, and legally required to restrict your account if it cannot get one. Ignoring the request does not take you out of the report, it just costs you your payouts.

Once filed, your figures go to the tax authority in the platform's member state of registration, then automatically to the country where you are tax resident, which can compare what the platform said you earned against what you declared. Sell across three platforms and three partial reports arrive, each showing a slice. The authority sees the combined picture, which is a good argument for making sure you do too.

You are entitled to see your own numbers. Annex V requires the platform to give you the information it reported about you, by that same 31 January deadline:

• Consideration broken down by quarter
• The number of relevant activities
• The fees and taxes withheld

Read it against your own records before you file anything.

The exposure is rarely the reporting itself. It is what the reporting reveals, such as a VAT registration threshold crossed quietly across several sales channels. Being reported is not an accusation. Every active seller on every in-scope platform is reported, and the calm response is to check that your own numbers match.

Does DAC7 apply to SaaS and digital product platforms?

The four relevant activities never mention software, digital products or content, and two definitions in Annex V explain why.

Goods are defined as any tangible property. Digital products are not tangible, so selling an ebook, a template pack or a downloadable course through a marketplace is not a sale of goods for DAC7 purposes.

A personal service is defined as time-based or task-based work performed by one or more individuals at the request of a user, online or offline, after being facilitated through the platform. Automated delivery of a file nobody worked on at a specific buyer's request does not fit that either.

Put those together and the picture is clearer than the search results suggest.

• A freelance or agency marketplace facilitates personal services, online or offline. In scope
• A course platform where independent instructors teach live sessions facilitates personal services. In scope
• A marketplace selling only pre-made digital downloads, with no human performing work at a buyer's request, matches neither definition. Generally outside the four relevant activities
• A SaaS company selling its own product to its own customers facilitates nothing between third parties, so DAC7 does not reach it at all

Getting your data ready

Every DAC7 problem is a data problem underneath:

• Tax IDs that were never collected.
• Consideration recorded as an annual total when the report wants quarters.
• Platform fees blended into gross figures instead of broken out.

Quaderno does not file DAC7 reports, and no invoicing tool does that for you. What it does is keep the layer underneath in a reportable state: tax and VAT numbers validated at checkout rather than chased later, per-transaction records with fees and taxes separated out, and reports you can pull for any period.

When a tax engine captures that as transactions happen, the January scramble turns into a query. That is the thinking behind Quaderno for platforms and marketplaces.

If your next question is whether your platform also has to collect VAT rather than just report on sellers, our guide to marketplace tax laws around the world covers the deemed supplier rules country by country.