DAC7 Reporting for Marketplace Sellers: What EU Brands Need to Know in 2026

By Operator One Editorial — 2026-06-14

Key takeaways

• DAC7 is Council Directive (EU) 2021/514: Member States had to transpose it by 31 December 2022 and it has applied since 1 January 2023, so the January 2026 filings covering calendar year 2025 were the third DAC7 reporting cycle.
• Under Annex V of Directive (EU) 2021/514, a seller of goods is excluded only if, on that platform, it made fewer than 30 sales and its total consideration did not exceed EUR 2,000 in the reportable period.
• The DAC7 excluded-seller test is applied per platform, so a brand trading on six EU marketplaces is typically reported in six separate DAC7 filings for the same year.
• Platforms must report to their tax authority, and send the same information to each reported seller, by 31 January of the following year; authorities then exchange it with other Member States within two months of the period ending.
• If a seller ignores a DAC7 data request, Annex V Section II requires the platform, after two reminders and no earlier than 60 days, to close the account or withhold payouts.
• The European Commission's DAC recast proposal COM(2026) 308 of 24 June 2026 would remove the 30-sale limb and raise the threshold to EUR 3,000 from 1 January 2028, but it is a proposal, not law.

DAC7, Council Directive (EU) 2021/514, has now completed three reporting cycles: calendar year 2023 (reported by 31 January 2024), calendar year 2024 (by 31 January 2025) and calendar year 2025 (by 31 January 2026). For brands selling on EU marketplaces, this means the tax authority of each Member State where they are resident receives, through automatic exchange, a quarterly picture of their marketplace consideration from every platform that reports them. Understanding what is reported, by whom and against which thresholds is the baseline for running a clean marketplace operation in the EU. The United Kingdom is outside DAC7 and runs its own, similar rules, covered below.

What DAC7 actually requires

Council Directive (EU) 2021/514, commonly known as DAC7, amended Directive 2011/16/EU on administrative cooperation in the field of taxation to bring digital platform operators inside the EU tax-transparency regime that already covered financial institutions. The Council adopted it on 22 March 2021. Member States had to transpose it by 31 December 2022 and apply it from 1 January 2023, and the first reports were filed by 31 January 2024 covering calendar year 2023.

Under Directive (EU) 2021/514, a reporting platform operator must collect and verify defined data about sellers who carry out relevant activities: the sale of goods, the rental of immovable property, personal services and the rental of any mode of transport. It reports that data once a year to the competent authority of its Member State, no later than 31 January following the reportable period. Under Article 8ac, that authority must then exchange the information with the Member State where each reportable seller is resident (and, for property rentals, where the property is located) within two months of the end of the reportable period. Platform operators that are not resident in the EU but facilitate relevant activities by EU-resident sellers, or rentals of EU property, must register in a single Member State and report there.

For brands selling physical products, the relevant activity is the sale of goods. That is the lane in which sellers on marketplaces such as Amazon, bol, Kaufland, Cdiscount, ManoMano, Allegro and Zalando are reported.

The thresholds that actually trigger reporting

Annex V, Section I of Directive (EU) 2021/514 defines four categories of excluded seller: a governmental entity; an entity whose stock is regularly traded on an established securities market (or a related entity of one); an entity for which the platform facilitated more than 2,000 rentals of immovable property for one listed property; and, for sellers of goods, a de minimis category. A seller of goods is excluded from DAC7 reporting for a reportable period only if both of the following are true on the same platform:

• The platform facilitated fewer than 30 sales of goods for the seller, and
• The total consideration paid or credited to the seller did not exceed EUR 2,000.

Reach 30 sales, or exceed EUR 2,000 in consideration, and the seller is reportable for that period on that platform. Under Directive (EU) 2021/514 the test applies per platform and is not aggregated across marketplaces, which is why a brand operating on six marketplaces will typically appear in six separate DAC7 reports even if its volume on any one of them is modest. For a brand running a serious cross-border marketplace programme, the de minimis exclusion is irrelevant in practice: it will be reported. A brand whose shares are regularly traded on an established securities market is, however, an excluded seller under Annex V regardless of volume.

The European Commission's DAC recast proposal, COM(2026) 308 of 24 June 2026, would remove the 30-transaction limb for sellers of goods and raise the monetary threshold to EUR 3,000, with Member States transposing by 31 December 2027 and applying the change from 1 January 2028. It is a proposal that requires unanimous adoption by the Council; the Directive (EU) 2021/514 test remains the law today.

The exact data points shared with tax authorities

The DAC7 data set is more detailed than most sellers initially realise. For every reportable seller that is an entity, Annex V, Sections II and III of Directive (EU) 2021/514 require the platform to collect and report:

• Legal name of the entity (or first and last name and date of birth for an individual)
• Primary address
• Any Tax Identification Number (TIN) issued to the seller, including each Member State of issuance
• VAT identification number, where available
• Business registration number (for example the Dutch KvK number, German Handelsregister number or Italian Registro Imprese number)
• The existence of any permanent establishment through which relevant activities are carried out in the EU, indicating each Member State concerned
• The financial account identifier to which consideration is paid or credited, insofar as it is available to the platform and the competent authority of the seller's Member State of residence has not publicly notified that it will not use it
• The name of the holder of that financial account, where different from the seller
• Per quarter of the reportable period: total consideration paid or credited, the number of relevant activities, and any fees, commissions or taxes withheld or charged by the platform

The quarterly granularity matters. Under Directive (EU) 2021/514, tax authorities receive four quarterly buckets of consideration and platform fees rather than a single annual figure, which can be set against quarterly VAT returns, EU OSS declarations and corporate tax filings. The platform must also provide each reported seller with the information reported about it by the same 31 January deadline, so a brand can check its own figures before any question arrives.

Brand-side implications

For brands, DAC7 changes three things at once.

VAT and OSS figures can be cross-checked. The gross consideration a platform reports about a brand under DAC7 can be compared with that brand's VAT returns and EU OSS declarations for the same quarter. Differences are normal (returns, refunds, currency conversion, payout timing and platform fees), and no EU tax authority publishes a tolerance for them, so the practical defence is a documented reconciliation for each platform and quarter.

Permanent establishment information is exchanged. Annex V of Directive (EU) 2021/514 requires platforms to collect whether the seller has a permanent establishment in the EU through which relevant activities are carried out, and in which Member State. DAC7 does not itself create a permanent establishment, but brands holding stock in fulfilment centres in several Member States need a documented PE and VAT registration position that is consistent with what they declare to each platform.

Entity data became load-bearing. The legal name, TIN, VAT number, business registration number and payout account that a seller registers on each marketplace are reported, as entered, to the competent authority and exchanged under Directive (EU) 2021/514. Mismatches between marketplace records and tax records, such as an outdated address, a payout account held by a different group company, or a VAT number belonging to an entity that has since been restructured, surface as data inconsistencies. This is also where the Merchant of Record model changes the picture: where a Merchant of Record is the registered seller, it is that entity's details that are reported for those sales, not the brand's.

The United Kingdom: similar rules, separate law

DAC7 does not apply in the United Kingdom. The UK implemented the OECD Model Reporting Rules through The Platform Operators (Due Diligence and Reporting Requirements) Regulations 2023 (SI 2023/817). The first UK reportable period was calendar year 2024, and reports were due to HMRC by 31 January 2025, with a copy of the information due to each reported seller by the same date. HMRC guidance states that platforms do not need to report sellers receiving EUR 2,000 or less for fewer than 30 sales of goods in a year. Under regulation 11 of SI 2023/817, a platform that files late faces a penalty of up to GBP 5,000 and, if the failure continues after a penalty notice, up to GBP 600 for each subsequent day.

Common errors that trigger flags

No EU tax authority publishes statistics on which DAC7 data errors lead to enquiries. In Operator One's experience of marketplace seller accounts, the data problems that most often cause friction are:

• TIN format errors: a TIN entered with spaces, a leading zero dropped by a spreadsheet, or the wrong issuing Member State attached to an otherwise valid number.
• Incomplete TIN information: an entity with TINs issued by more than one Member State that registered only one on the marketplace, although Annex V of Directive (EU) 2021/514 asks for each TIN and each Member State of issuance.
• Payout account held by a different legal entity: common after restructurings, or when a holding company's account receives payouts for an operating subsidiary. DAC7 reports the account holder name where it differs from the seller.
• Unreconciled quarterly figures: DAC7 quarterly consideration that differs from the same quarter's VAT or OSS figures with no documented reconciliation for returns, refunds or fees.
• No documented permanent establishment position: stock held in fulfilment centres in a Member State without a considered PE and VAT registration position for that country.
• Stale legal address: a registered address that has changed but was never updated on the marketplace account, so correspondence does not arrive.

The remediation pattern is consistent: correct the master data on every platform at the same time (fixing one account while others lag creates new inconsistencies), take advice on whether a VAT, OSS or corporate tax return needs correcting in the Member State concerned, and document the chain of changes so the next reporting cycle reconciles cleanly. Also note the consequence of not responding: under Annex V, Section II of Directive (EU) 2021/514, if a seller has not provided the required data after two reminders following the platform's initial request, and no earlier than 60 days, the platform must close the seller's account and prevent re-registration, or withhold payment of the consideration. Platforms carry their own penalties as well: section 25 of Germany's Plattformen-Steuertransparenzgesetz (PStTG) sets fines of up to EUR 50,000, EUR 30,000 or EUR 5,000 depending on the infringement. See the compliance glossary for the definitions used in this article.

How to prepare for DAC7 reporting, step by step

1. Map every marketplace account: List each EU marketplace account, the legal entity registered on it and whether that entity or a Merchant of Record is the seller, because the DAC7 test under Directive (EU) 2021/514 applies per platform.
2. Align master data with tax records: Make the legal name, primary address, each TIN, VAT identification number and business registration number on every marketplace account match the entity's national tax and company registers.
3. Check the payout account: Confirm that the IBAN receiving payouts belongs to the registered seller entity, since DAC7 reports the account holder name when it differs from the seller.
4. Answer platform data requests promptly: Respond to DAC7 due diligence requests before the second reminder, because after two reminders and 60 days Annex V requires the platform to close the account or withhold payouts.
5. Reconcile the seller copy by quarter: When each platform sends its DAC7 information by 31 January, reconcile the quarterly consideration and fees to your VAT and OSS returns and document differences such as returns and refunds.

Frequently asked questions

Do I have to be reported under DAC7 if I only sell a small volume on Amazon Germany?

Under Annex V of Directive (EU) 2021/514 you are an excluded seller only if both conditions hold on that one platform in the calendar year: fewer than 30 sales of goods, and total consideration not exceeding EUR 2,000. Cross either limb and Amazon reports you for the whole year. Because the test runs per platform, a brand on six marketplaces faces six independent tests and usually six DAC7 reports.

What is the DAC7 reporting deadline, and does the marketplace have to tell me what it filed?

Directive (EU) 2021/514 requires reporting platform operators to file with their Member State's competent authority no later than 31 January following the reportable period, so calendar year 2025 data was due by 31 January 2026. By the same 31 January date the platform must give each reported seller the information reported about them, so every DAC7-reported brand should receive its own copy from each marketplace.

What exact data does a marketplace send to the tax authority about me under DAC7?

For an entity seller, Annex V of Directive (EU) 2021/514 covers the legal name, primary address, each TIN and its issuing Member State, VAT identification number, business registration number, and any EU permanent establishment with its Member State. Per quarter it adds total consideration, the number of sales, and fees, commissions or taxes the platform withheld or charged, plus the payout account identifier where available and the account holder name.

What happens if I ignore a marketplace's DAC7 information request?

Section II of Annex V to Directive (EU) 2021/514 obliges the platform to act. If a seller has not supplied the data after two reminders following the first request, and no earlier than 60 days, the platform must close the account and block re-registration, or withhold payment of the consideration. Platforms face their own fines too: up to EUR 50,000 under section 25 of Germany's PStTG, and up to GBP 5,000 plus GBP 600 a day in the UK.

Who gets reported under DAC7 when a Merchant of Record is the seller?

Under Directive (EU) 2021/514 the platform reports the seller registered on its platform that receives the consideration. Where a Merchant of Record such as Operator One is the registered seller, the DAC7 report carries that Merchant of Record's legal name, TIN, VAT number, business registration number and payout account, not the brand's. The brand's own corporate income tax, transfer pricing and bookkeeping obligations are unaffected, and any lane where the brand sells in its own name remains reportable.

Does DAC7 apply to UK marketplace sales?

No. DAC7 is EU law and does not apply in the United Kingdom. The UK adopted the OECD Model Reporting Rules through The Platform Operators (Due Diligence and Reporting Requirements) Regulations 2023 (SI 2023/817). The first UK reportable period was calendar year 2024, with reports due to HMRC by 31 January 2025. HMRC guidance applies a similar excluded-seller test: fewer than 30 sales of goods and EUR 2,000 or less.

Is the DAC7 EUR 2,000 threshold changing?

Not for current filings. On 24 June 2026 the European Commission proposed a recast of the Directive on Administrative Cooperation, COM(2026) 308, which would remove the 30-transaction limb for sellers of goods and raise the monetary threshold to EUR 3,000. The draft sets transposition by 31 December 2027 and application from 1 January 2028, subject to unanimous Council adoption. Until then the Directive (EU) 2021/514 test stands.

Why would tax authorities compare my DAC7 figures with my VAT and OSS returns?

DAC7 under Directive (EU) 2021/514 reports consideration and platform fees per quarter, so each quarter can be set against the same quarter's VAT return or EU OSS declaration. Article 8ac requires the receiving authority to pass the data to the seller's Member State of residence within two months of the reportable period ending. No EU tax authority publishes a tolerance for differences, so documented reconciliations for returns, refunds and fees matter.

Does using fulfilment centres in several EU countries create permanent establishment risk under DAC7?

DAC7 does not create a permanent establishment. However, Annex V of Directive (EU) 2021/514 requires the platform to collect the existence of any permanent establishment through which the seller carries out relevant activities in the EU, naming each Member State, and that data is exchanged. A brand holding stock in fulfilment centres across several Member States therefore needs a documented PE and VAT position consistent with its platform declarations.

Where a Merchant of Record carries the obligation

DAC7 reporting is an obligation of the platform operator, not the seller; the seller's role is to supply accurate data and to reconcile what is reported. Under Directive (EU) 2021/514 the platform reports the seller registered on its platform. Where Operator One acts as Merchant of Record, Operator One is the legal seller and the registered seller on the marketplace (listings show the client as the brand and Operator One as the seller), so the DAC7 report for those sales carries Operator One's entity data and payout account. The brand's own corporate income tax, transfer pricing and bookkeeping obligations are unaffected, and any marketplace account the brand still operates in its own name remains reportable under DAC7 in the brand's name. Terms used here are defined in the compliance glossary.

Sources: Council Directive (EU) 2021/514 (DAC7), EUR-Lex; European Commission, Directive on Administrative Cooperation; European Commission, tax simplification package, 24 June 2026; COM(2026) 308, DAC recast proposal, explanatory memorandum; UK SI 2023/817; SI 2023/817, regulation 11; HMRC, check if you need to register as a digital platform operator; HMRC, reporting rules for digital platforms; Germany, PStTG section 25.