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DAC7 readiness check

Due diligence has to be complete by 31 December of the reportable period and the return is due by 31 January. Neither deadline moves, and the data behind them cannot be collected retrospectively.

These are the questions worth answering honestly while there is still time to act on the answers — including the two that catch most people out: the quarterly split of fees and taxes, and amounts reported in whole units of currency.

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Scope and registration

Have you established, with an adviser, whether you are a Reporting Platform Operator, and in which Member State you report?

The definition is broader than the word 'platform' suggests: any software allowing sellers to connect with users to carry out a Relevant Activity. A booking site, a jobs marketplace and a delivery app can all qualify.

Do you know which single Member State you register in, and have you registered there?

An operator with a presence in several Member States picks one and reports everything through it. A non-EU operator registers in a Member State of its choosing.

Can you identify Excluded Sellers — government entities, listed entities, large hotel operators, and small-volume goods sellers?

Excluded Sellers are not reported at all. The goods threshold is fewer than 30 sales for no more than EUR 2 000 in the period, and it is assessed per seller per year.

Data you must hold

Do you hold, for every Reportable Seller, the identity details DPI requires — name, address, TIN and its issuing Member State?

For entities that also means the business registration number; for individuals, the date of birth. These are the due-diligence records behind everything in the return.

Where applicable, do you hold each seller's VAT identification number and any permanent establishments through which they operate in the EU?

Both are reported where available. Permanent establishments are an EU-specific element and are reported per Member State.

Can your systems produce consideration, number of activities, fees and taxes per seller per activity, split by the quarter in which each was paid or credited?

DPI reports four quarters, not an annual total, and it reports fees and taxes you withheld as well as the consideration itself. The split is by when the money moved, not when the activity happened.

Does your export report amounts in whole units of currency, without decimals?

DPI amounts are whole units — 1250, not 1250.00. It is the single most common failure when an exporter is adapted from a CRS or CARF one, and it fails schema validation outright.

If you facilitate rental of immovable property, do you hold the address, land registration number and days rented for each listing?

Property is reported listing by listing, with its own quarterly figures, and grouped by property rather than by booking.

Process and evidence

If another platform operator reports on your behalf, or you on theirs, do you hold the evidence of that arrangement?

The schema records assumed reporting explicitly and names the other operator. It is a claim that somebody else discharged your obligation, and it has to be supportable.

Do you tell sellers what you report about them, as GDPR requires?

Reporting a seller's income to a tax authority is processing personal data. The information has to be provided to the seller in time for them to exercise their rights.

Where a seller fails to provide their details after two reminders, do you have a process to close their account or withhold payment?

The Directive expects the operator to act after reminders rather than simply file an incomplete record. The dates of what was sent are the evidence that you did.

Filing and corrections

Do you have a way to correct or delete a reported seller after filing, referencing what was originally sent?

A correction points at the DocRefID of the record it replaces and must reference the latest version sent. That means a durable ledger of every identifier you have issued.

Have you produced a test file in the DPI XML format and validated it end to end?

The first time a return is generated is the wrong time to discover that the quarterly totals do not add up or that the amounts carry decimals.

Unanswered questions count as gaps. You can go back and change anything.

Reporting under a different regime? Run the CARF / DAC8 checklist