As Belgium enters the third year of DAC7 reporting, the regime is now well established. For many businesses, DAC7 has become a recurring compliance obligation, yet its complexity and the ongoing increase of non-EU countries adopting similar regimes continue to create new challenges. This newsflash offers a concise recap of DAC7 and highlights key focus areas — based on our experience — around data collection and compliance.
Short recap: What is DAC 7?
In March 2021 the Council of the European Union adopted new transparency rules in the field of taxation under the Directive on administrative cooperation (DAC). These rules require platform operators to annually report specific information about sellers and the considerations they receive on the platform to the government, and to fulfill related due diligence obligations.
Those rules needed to be implemented by all the EU Member States by 31 December 2022, consequently entering into force on 1 January 2023 in Belgium.
Several key attention points
- Sellers with identical names and different addresses: Similar or identical seller names often appear multiple times, sometimes linked to different addresses. Clear rules for identifying, matching, and consolidating records help avoid duplicate or inconsistent reporting (due diligence obligation).
- Blank or incomplete fields: Another recurring problem is incomplete information in mandatory data fields. Detecting missing mandatory information only at the end of the year near the reporting deadline poses a direct risk of non-compliance as gathering this information at that time proves to be difficult or near impossible. Pro-active validation processes are thus critical.
- Developments in legislation: Companies should also monitor legislative developments that continue to shape the DAC7 framework. In Belgium, a law adopted at the end of last year requires platform operators to share the information to be reported with the individual sellers by no later than 10 January, before filing with the Belgian competent authority—an deviation from the previous 31 January deadline.
- Developments outside the EU: Other countries outside the EU, such as Canada, the United Kingdom, and New Zealand have implemented similar reporting obligations. This demonstrates that the impact on your business could extend well beyond the EU if you are active in these jurisdictions.
Looking Ahead
To address the above challenges, companies need to be aware of the next key dates:
- 31 December 2025 for the completion of due diligence procedures for the reporting period 2025.
- 10 January 2026 to share the collected information with the sellers on the platform.
- 31 January 2026 for the submission of the collected information to the Belgian competent authority (reporting obligation).
In case you would like to know more about the DAC 7 reporting obligation or if you have a client which might be in scope, please reach out to Pieter Deré (BE), Niels D’Hondt (BE) or Elisa Debersaques (BE)
