Optional deferral of the reporting obligation – Germany opts out


The Council Directive (EU) 2020/876 of 24 June 2020, amended the DAC 6 Directive by deferring the reporting deadlines by 6 months. Since the deferral is included in the Directive, an implementation is required in order to be reflected in the domestic legislation of the different Member States.

Given the optional character of the amendment (and subsequently the deferral) however, it is up to the different Member States to decide on the deferral. In this respect, Germany has announced on 6 July 2020 that Germany will not be exercising the option to modify the reporting deadlines provided by the recent amendment.

As a reminder: also Finland and Austria have opted not to exercise the deferral option.

This optional deferral will certainly increase uncertainty as regards the timing of the reporting obligation and it will be key to closely monitor the status of the implementation of the optional deferral in the key countries for your organisation. Click here for further information


For more insights and support, contact your local PwC advisor or Pieter Deré.