DAC7 deadline 31 January 2026: Key actions for EU and non-EU platform operators

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With the 31 January 2026 DAC7 reporting deadline fast approaching, platform operators, whether established inside or outside the EU, are entering the final stage of preparing their annual compliance submissions. DAC7, which has applied since 1 January 2023, introduced a harmonized framework requiring platform operators to collect, verify, and report information on sellers carrying out certain commercial activities through digital platforms. The upcoming filing relates to the 2025 calendar year, and timely preparation remains essential. 

1. What platform operators need to finalize before 31 January 2026

In the coming two weeks, platform operators should ensure that they have completed the due diligence procedures set out under DAC7. This includes gathering and validating data on all reportable sellers, such as their identification details, tax identification numbers, and payment information, tasks that many platforms continue refining as part of their internal compliance processes. These due diligence steps form the basis of the annual DAC7 report. 

Equally important is ensuring that all activities falling within the scope of DAC7 have been captured. These include the sale of goods, rental of immovable property, provision of personal services, and rental of means of transport, categories that reflect the diversity of the platform economy. 

Once due diligence and data validation are complete, platform operators must submit their DAC7 report to the competent authority of the EU Member State where they are domiciled or have registered by 31 January 2026. The possibility to report through one EU Member State remains a practical simplification for platforms with activities spanning multiple EU jurisdictions

2. Why non EU platforms must pay close attention

Although DAC7 is an EU measure, its application is not limited to EU‑established platforms. Non EU platform operators must also comply if they facilitate relevant activities performed by EU-based sellers or involving immovable property located in the EU. This broader application is intentional and acknowledges the increasingly cross‑border character of platform‑based activities.

Non EU platforms are required to register in a single EU Member State, complete the DAC7 due diligence for reportable sellers with EU nexus, and submit their report by the same 31 January deadline. Penalties for non‑compliance vary among Member States, but can be substantial, underscoring the need for timely and accurate reporting. 

3. Cross border exchange of DAC7 information: beyond the EU

DAC7 is part of a broader international effort to enhance tax transparency through the automatic exchange of information. Importantly, information reported under DAC7 is not limited to exchanges within the EU. Through the OECD Multilateral Competent Authority Agreement on Automatic Exchange of Information on Income Derived through Digital Platforms (DPI MCAA), the EU framework interacts with wider international exchange mechanisms. This means that, where an EU Member State has activated exchange relationships with non‑EU jurisdictions applying DAC7‑equivalent rules, platform operators may also be required to collect and report information relating to sellers who are resident in, or who rent out immovable property located in, those jurisdictions.

For platform operators reporting in the Netherlands, information submitted under DAC7 or the OECD MRDP will be exchanged with Canada, New Zealand, and the United Kingdom, each of which has activated information exchange relationships with the Netherlands as of 2025.

This broader exchange network is particularly relevant for platforms with a global seller base or cross‑border operations, as it may expand the scope of the information they must collect and report.

Why timely DAC7 compliance matters

As the 31 January 2026 deadline approaches, platform operators, both EU and non‑EU, should ensure that their due diligence obligations have been fulfilled, their reporting systems are ready, and their datasets are complete and accurate. DAC7 continues to be a significant development in tax transparency, reinforced by an expanding network of international exchange relationships. Meeting the upcoming deadline will not only ensure compliance but also support the integrity and reliability of platform‑based business models.

More information?

If you have any questions or would like to learn more about how DAC7 may affect your organisation, our team is available to help. Please feel free to contact us.

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