DAC7 Reporting for Luxembourg Platform Operators: Who Reports, What Data, and When

Updated September 2026

If you are a Luxembourg Platform Operator required to register with the ACD and have not done so, the applicable registration deadline has been missed. Luxembourg exceptionally extended the filing deadline for the 2023 report to 19 February 2024. The 2024 report was due on 31 January 2025 and the 2025 report was due on 31 January 2026. The 2026 report is due by 31 January 2027.

DAC7 is the sixth amendment to Directive 2011/16/EU on administrative cooperation in tax matters. Council Directive (EU) 2021/514 of 22 March 2021 introduced mandatory reporting obligations for digital platform operators across the EU. Luxembourg transposed it through the Law of 16 May 2023, published in the Mémorial A No. 237 on 19 May 2023. The law entered into force on 1 June 2023, but reporting obligations applied retroactively to transactions from 1 January 2023.

The regime is modelled on the OECD Model Rules for Reporting by Platform Operators with respect to Sellers in the Sharing and Gig Economy, published in July 2020. If your firm is already familiar with CRS or FATCA logic, the structure will feel recognisable: collect seller data, verify it, report it annually to the tax authority, and let the automatic exchange do the rest. The compliance burden sits entirely with the platform operator. Sellers carry no reporting obligations of their own.

Related reading: CARF Crypto Tax Reporting – covers the parallel reporting framework for crypto-asset service providers under the OECD’s Crypto-Asset Reporting Framework.

Who Qualifies as a Reporting Platform Operator

The DAC7 Law defines a Platform broadly as software, including a website or application, that allows Sellers to connect with other users for the purpose of carrying out a Relevant Activity directly or indirectly. An arrangement for collecting and paying Consideration is included within the definition, but payment handling is not a mandatory element. Software is excluded where, without further intervention in the Relevant Activity, it exclusively processes payments, allows users to list or advertise a Relevant Activity, or redirects or transfers users to another Platform.

Two categories of entities qualify as Reporting Platform Operators under the Luxembourg law.

EU Platforms and Foreign Platforms

The first category includes a Platform Operator that is tax-resident in Luxembourg or, where it has no tax residence in another EU Member State, is incorporated under Luxembourg law, has its place of management, including effective management, in Luxembourg, or has a permanent establishment in Luxembourg.

The second category can capture Platform Operators with no EU residence, incorporation, management or permanent establishment where they facilitate Relevant Activities by Reportable Sellers or rental of immovable property located in an EU Member State. This third-country limb does not apply to a Qualified Non-Union Platform Operator, and qualifying equivalent exchange arrangements can produce a complete or partial exemption.

A Luxembourg-nexus Reporting Platform Operator that qualifies in more than one Member State may elect one of those Member States for reporting and must notify the ACD where it elects another Member State. By contrast, a third-country Reporting Platform Operator that chooses another Member State as its single Member State of registration is not required to register, notify or report to the ACD solely because it has Luxembourg Reportable Sellers.

What Is Not a Platform Under DAC7

The law excludes software that exclusively performs one or more of the following functions without any further intervention in the relevant activity: payment processing, user listing, advertising, or redirection to another platform. Pure payment processors and pure ad networks fall outside the definition. The key test is whether the software facilitates the activity itself. The statutory exclusion is limited to software that, without further intervention in the Relevant Activity, exclusively performs the specified payment-processing, listing or advertising, or redirection functions; other functionality must be assessed against the Platform definition.

Reportable Activities

DAC7 targets income generated through platforms, but not all platform activity falls within scope. The relevant activities are:

• Rental of immovable property, including residential and commercial real estate
• Provision of personal services, defined as time- or task-based work performed by individuals, whether online or offline, facilitated via the platform
• Sale of goods
• Rental of any mode of transport

Crowdfunding is not itself one of the four Relevant Activities listed in Annex V. Whether a crowdfunding platform falls outside DAC7 therefore depends on whether its model also facilitates any of the defined Relevant Activities.

A Personal Service is time- or task-based work performed by one or more individuals, independently or on behalf of an Entity, at a user’s request, either online or physically offline after being facilitated via a Platform. However, a Relevant Activity does not include an activity carried out by a Seller acting as an employee of the Platform Operator or of a related Entity of the Platform Operator. Collection of the payment by the Platform Operator is not a separate condition of the Platform definition.

Relevant Activity includes the rental of residential and commercial property, other immovable property and parking spaces for Consideration. DAC7 does not require that the Consideration be collected or processed by the Platform Operator.

Reportable Sellers and the Exclusion Thresholds

Not every seller on a platform needs to be reported. A Reportable Seller is a platform user, whether an individual or an entity, who carries out a relevant activity for consideration and is resident in an EU Member State, or rents out immovable property located in an EU Member State. Excluded Sellers include Governmental Entities; an Entity whose stock is regularly traded on an established securities market or a related Entity of such an Entity; an Entity for which the Platform Operator facilitated more than 2,000 immovable-property rental Relevant Activities in respect of a Property Listing during the Reporting Period; and a goods seller meeting the separate fewer-than-30 and EUR 2,000 exclusion.

For goods sellers specifically, an exclusion applies where the Platform Operator facilitated fewer than 30 Relevant Activities involving the sale of Goods for the Seller during the Reporting Period and the total Consideration paid or credited did not exceed EUR 2,000. Both conditions must be satisfied. Exactly 30 goods-sale Relevant Activities fails this exclusion, whereas exactly EUR 2,000 remains within it if the activity count is below 30.

There is no comparable low-value or low-volume exclusion for personal services, transport rental or immovable-property rental. Subject to the other Excluded Seller categories and the applicable residence or property-location tests, a Seller can therefore become reportable after a single Relevant Activity.

An Entity whose stock is regularly traded on an established securities market, and any related Entity of such an Entity, is an Excluded Seller.

Due Diligence Procedures

The reporting obligation is only as good as the underlying data. DAC7 requires Reporting Platform Operators to carry out defined due diligence procedures to identify Reportable Sellers before reporting.

Data You Must Collect

For an individual Seller who is not an Excluded Seller, the due-diligence information includes first and last name, Primary Address, any TIN and each Member State of issuance and, in the absence of a TIN, place of birth, VAT identification number where available, and date of birth. For an Entity Seller, it includes legal name, Primary Address, any TIN and Member State of issuance, VAT identification number where available, business registration number and, where available, any permanent establishment through which Relevant Activities are carried out in the Union and its Member State. Statutory exceptions apply where the Seller’s Member State of residence does not issue a TIN or business registration number, as applicable. Separately, a TIN need not be collected where that Member State does not require collection of the TIN issued to the Seller. The Financial Account Identifier is a separate reporting field, required only insofar as it is available and the Seller’s residence Member State has not opted out of its use.

In addition to Seller identity information, the report contains quarterly aggregates for each Reportable Seller: total Consideration paid or credited, the number of Relevant Activities and any fees, commissions or taxes withheld or charged. For immovable-property rental it also includes each Property Listing address, the land-registration number or equivalent where available, quarterly Consideration and Relevant Activity counts for each Property Listing and, where available, the number of rental days and type of Property Listing.

Quarterly granularity is part of the reporting requirement: DAC7 requires Consideration, Relevant Activity counts and fees, commissions or taxes withheld or charged to be reported by quarter, with property-level quarterly amounts and counts for immovable-property rentals. Annual totals alone therefore do not satisfy the reporting requirement. If your platform only stores annual aggregates, you need to fix your data architecture before the next filing cycle, not after.

Verification Requirements

The Reporting Platform Operator must determine whether the specified Seller information is reliable using information and documents available in its records and any free electronic interface made available by a Member State or the Union for validating a TIN or VAT identification number. Where the specific Annex V correction trigger applies because information supplied by a competent authority in a request concerning a particular Seller gives the operator reason to know that information may be inaccurate, the operator must request correction and reliable independent supporting documentation. Seller residence is determined under the Annex V residence rules, principally from the Primary Address, with additional Member State residence arising from the applicable TIN, permanent-establishment or Identification Service rules; the country of a payment account is not itself a DAC7 residence test.

Due Diligence Deadlines

Due diligence must generally be completed by 31 December of the Reportable Period. For Sellers already registered on the Platform as of 1 January 2023, or as of the date on which an Entity becomes a Reporting Platform Operator, the procedures may instead be completed by 31 December of the Reporting Platform Operator’s second Reportable Period. The ACD therefore gave 31 December 2024 as the deadline for Sellers already registered on 1 January 2023.

What to Report

The annual report must contain the information required for each Reportable Seller under Annex V, including the applicable Section II Seller information; the Financial Account Identifier where required and available; where the financial-account holder’s name differs from the Reportable Seller, that holder’s name and any other available financial identification information relating to the holder; each Member State of residence; quarterly total Consideration and Relevant Activity counts; and quarterly fees, commissions or taxes withheld or charged. Where the Reporting Platform Operator reports to a competent authority that uses an Identification Service and relies on direct confirmation through that service to establish the Seller’s identity and all tax residencies, the Section II paragraph B Seller-information items need not be reported; instead, the Seller’s name, Identification Service identifier or identifiers and Member State or States of issuance are reported. For immovable-property rental, the report also includes each Property Listing address, land-registration number or equivalent where available, quarterly Consideration and Relevant Activity count for each Property Listing and, where available, rental days and property type.

The ACD then exchanges this information automatically with the tax authorities of the relevant EU Member States, based on the seller’s residence and the location of the property. A Luxembourg platform reporting a French-resident seller who rents out a Paris apartment will see that data forwarded to the French tax authorities. This is the core mechanism: the platform’s report triggers cross-border automatic exchange.

Fiat Consideration is reported in the currency in which it was paid or credited. Non-fiat Consideration is reported in the Seller’s local currency using a consistently determined conversion or valuation. For the Luxembourg XML, where Consideration for the reporting period has been paid in different currencies, the ACD requires those amounts to be converted into one reporting currency; the ACD gives EUR as an example and specifies the relevant annual average exchange rate methodology.

Filing with the ACD: Registration and Annual Declaration

Registration on MyGuichet

Luxembourg Reporting Platform Operators must register with the ACD via the dedicated procedure on MyGuichet, the Luxembourg government’s secure electronic portal. The registration deadline for operators active from 1 January 2023 was 31 December 2023. Operators starting activity after that date must register no later than the date they begin operating.

The ACD newsletter of 12 June 2023 confirmed the MyGuichet registration route and directed operators to the “Echanges electroniques” section of the ACD website for technical documentation. If your platform has not yet registered and you are reading this after the fact, the first step is to register immediately and then assess what remediation is needed for the missed reporting periods.

Annual Reporting Deadline and XML Format

Annual declarations are generally due by 31 January of the year following the Reportable Period. Luxembourg exceptionally postponed the 2023 reporting-year filing deadline to 19 February 2024. The 2024 report was due on 31 January 2025, the 2025 report on 31 January 2026, and the 2026 report is due by 31 January 2027.

Luxembourg declarations are transmitted through MyGuichet using the current DAC7 XSD and validation rules published by the ACD. The OECD’s DPI XML Schema is Version 1.0, updated in April 2023, and was designed to facilitate DAC7 exchanges, but operators should build and validate against the current technical package published by the administration through which they file rather than assume that every Member State uses an identical submission specification.

Validate the XML against the XSD before uploading. The ACD will reject malformed files. Build the validation step into your processing pipeline before you build anything else.

Can a Group File a Single DAC7 Report Covering Multiple Entities?

DAC7 attaches the reporting obligation to each Platform Operator as a separate legal entity. Corporate groups have no consolidated filing mechanism under this directive. Scope is assessed platform by platform, entity by entity. The directive contains a duplicate-reporting exemption where the same information has already been reported by another Reporting Platform Operator and the relying operator holds the required proof. Separately, the single-Member-State election applies only where the same Reporting Platform Operator qualifies in more than one Member State; it does not allow one group entity to satisfy another group entity’s reporting obligation merely because both belong to the same group.

A Platform Operator is an Entity that contracts with Sellers to make all or part of a Platform available to them. Each group entity meeting that definition must separately assess whether it is a Reporting Platform Operator. Collection or payment of Consideration is not a separate condition for Platform Operator status, and the existence of a shared group Platform does not by itself identify a single reporting entity.

The first mechanism is the single-reporting exemption in Annex V of DAC7. Where there is more than one Reporting Platform Operator, any of them is exempt from reporting the information if it has proof, in accordance with national law, that the same information has already been reported by another Reporting Platform Operator. Inside a group, this means one entity can file the report while the affiliated entities that would otherwise report the same sellers and transactions are relieved of the duplicate filing. This is the closest DAC7 comes to a single group report. It operates as an entity-level exemption that depends on evidence, and it stops short of a consolidated return.

The duplicate-reporting exemption applies where a Reporting Platform Operator has proof that the same information has been reported by another Reporting Platform Operator. It does not create an exemption from the Section II due-diligence obligations. A Reporting Platform Operator may rely on a third-party service provider or another Platform Operator to perform due diligence, but those due-diligence obligations remain the responsibility of the Reporting Platform Operator.

The second mechanism addresses operators that qualify in more than one country. Where a Reporting Platform Operator with an EU nexus meets the qualifying conditions in more than one Member State, the directive requires it to elect one Member State in which to report and to notify all the competent authorities concerned of that election. A group entity that is tax-resident in Luxembourg may elect another Member State only where it also satisfies the Section I.A.4(a) nexus in that other Member State, for example by also being tax-resident there. Where the operator has no tax residence in any Member State, the election can instead arise where it satisfies the applicable incorporation, place-of-management or permanent-establishment conditions in more than one Member State. It reports in the elected Member State and notifies the competent authorities concerned.

A Luxembourg-nexus Reporting Platform Operator that qualifies in more than one Member State and elects another Member State for reporting must notify that election to the ACD; the election relieves the Luxembourg reporting obligation but does not create a general exemption from Luxembourg registration. A Reporting Platform Operator relying on the duplicate-reporting exemption must hold proof that the same information was reported by another Reporting Platform Operator. Separately, a third-country Reporting Platform Operator that selects another Member State as its single Member State of registration is not required to register, notify or report to the ACD on that basis.

Before the filing deadline, a group should identify every legal entity that meets the Platform Operator and Reporting Platform Operator tests. An election between Member States applies only where the same Reporting Platform Operator qualifies in more than one Member State, while the duplicate-reporting exemption applies only where the same information has actually been reported by another Reporting Platform Operator and the relying operator holds the required proof.

Penalties for Non-Compliance

Under the Luxembourg DAC7 regime, failure to comply with the legal deadline for registration, notification or declaration can attract a flat EUR 5,000 fine. The same EUR 5,000 fine applies to incorrect or incomplete information supplied during registration. Separately, following an audit, the ACD may impose a fine of up to EUR 250,000 where a Platform Operator has failed to comply with its due-diligence procedures or reporting obligations.

Frequently Asked Questions

Does DAC7 apply to platforms incorporated outside the EU that have Luxembourg sellers?

Potentially. A Platform Operator with no EU residence, incorporation, management or permanent establishment can fall within DAC7 where it facilitates Relevant Activities by Reportable Sellers or EU-located immovable-property rental, but the Qualified Non-Union Platform Operator and equivalent-exchange rules must first be checked. A third-country Reporting Platform Operator that remains subject to EU registration selects a single Member State of registration and may select Luxembourg.

What if my platform already reports in Germany? Do I need to file separately in Luxembourg?

It depends on the operator’s nexus. A Luxembourg-nexus Reporting Platform Operator that also qualifies in Germany and elects Germany for reporting must notify the ACD and does not file the same DAC7 report separately in Luxembourg. A third-country Reporting Platform Operator whose single EU registration is in Germany is not required to register, notify or report to the ACD merely because it has Luxembourg Reportable Sellers.

The goods exclusion is met for a seller at mid-year. Do I still have to track them for the rest of the year?

Yes. The goods exclusion is assessed using the full Reporting Period. It applies only where fewer than 30 goods-sale Relevant Activities were facilitated and total Consideration did not exceed EUR 2,000. Accordingly, 30 activities fail the exclusion, while Consideration must exceed EUR 2,000 before the monetary limb fails.

A seller refuses to provide their TIN. What do I do?

Where a Seller does not provide information required under Section II, after the initial request and two reminders, but not before 60 days have expired, the Reporting Platform Operator must either close the Seller’s account and prevent re-registration or withhold payment of Consideration until the requested information is provided. The rule applies to required Section II information, not only to a TIN.

How does the platform determine a seller’s EU residence if the seller claims to be outside the EU?

For DAC7 purposes, the Seller is generally treated as resident in the Member State of its Primary Address and additionally in another Member State where the applicable TIN or permanent-establishment information so indicates; an Identification Service can also establish residence where used under the amended rules. The ACD states that, for a Relevant Activity other than immovable-property rental, a Seller without a Primary Address in an EU Member State is not a Reportable Seller merely because its TIN or permanent establishment is in an EU Member State. The location of a payment account is not itself a DAC7 residence test.

Is there a minimum consideration amount for personal services sellers to become reportable?

There is no comparable low-value or low-volume exclusion for personal services, transport rental or immovable-property rental. However, the Seller must still satisfy the Reportable Seller test and must not fall within another Excluded Seller category, including the listed-Entity, Governmental Entity and qualifying high-volume immovable-property-rental exclusions.

Can I use a third-party vendor to file the DAC7 report on my behalf?

A Reporting Platform Operator may use a third-party service provider to perform due-diligence work, but those obligations remain the responsibility of the Reporting Platform Operator. Luxembourg requires the DAC7 declaration to be transmitted electronically through the dedicated MyGuichet procedure. Whether an external adviser can submit the DAC7 declaration under a MyGuichet mandate depends on the current list of services eligible for digital mandate and should be checked in MyGuichet before relying on delegated submission.

Related Articles

• CARF Crypto Tax Reporting: covers the OECD Crypto-Asset Reporting Framework, which has been transposed in Luxembourg under DAC8 by the Law of 27 March 2026.
• CESOP Reporting Explained: covers the Central Electronic System of Payment Information, under which payment service providers must keep prescribed records of qualifying cross-border payments and the reporting requirement is triggered where more than 25 cross-border payments are made to the same payee in a calendar quarter, subject to the regime’s other scope rules. Different scope from DAC7 but similar tax-authority information-exchange mechanics.
• AML Reporting Luxembourg: DAC7 data flows can intersect with AML/KYC processes: the seller identification procedures required under DAC7 draw on similar data to that collected for anti-money laundering customer due diligence.

Key Takeaways

• DAC7 has applied to Reportable Periods from 1 January 2023. Luxembourg transposed it through the Law of 16 May 2023. Luxembourg exceptionally postponed the deadline for the first report, covering 2023, to 19 February 2024.
• A Platform Operator is an Entity that contracts with Sellers to make all or part of a Platform available; Reporting Platform Operator status then depends on the applicable EU-nexus or third-country tests. Handling Consideration is not a mandatory condition, and the third-country rules contain Qualified Non-Union and equivalence carve-outs.
• Relevant Activities are immovable-property rental, Personal Services, sale of Goods and rental of any mode of transport. The goods exclusion applies where fewer than 30 goods-sale Relevant Activities are facilitated and Consideration does not exceed EUR 2,000, but DAC7 also contains separate Excluded Seller categories for Governmental Entities, listed Entities and their related Entities, and qualifying high-volume immovable-property rental by Entities.
• Groups do not file on a consolidated basis. Each Platform Operator is a separate reporting entity, but one entity can carry the filing where the others hold proof the same information was reported, and an operator qualifying in several Member States elects one and notifies the rest.
• Due diligence must generally be completed by 31 December of each Reportable Period. For Sellers already registered on 1 January 2023, or on the date an Entity becomes a Reporting Platform Operator, the deadline is 31 December of the second Reportable Period.
• Reports are filed electronically via MyGuichet using the current DAC7 XSD and validation rules published by the ACD. The ACD provides a pre-validation procedure that validates the XML against the XSD and applicable business rules.
• Luxembourg Platform Operators subject to the registration obligation register electronically through MyGuichet; operators beginning activity after 31 December 2023 generally register no later than the start of that activity. Specific exemptions apply, including for certain third-country operators using another Member State as their single registration state and for qualifying equivalent-exchange cases.
• A flat EUR 5,000 fine applies to specified failures concerning registration, notification or declaration deadlines and incorrect or incomplete registration information. Separately, following an ACD audit, breaches of due-diligence or reporting obligations can attract a fine of up to EUR 250,000.
• DAC7 can apply to third-country Platform Operators facilitating Relevant Activities for Reportable Sellers or EU-located immovable-property rental, subject to the Qualified Non-Union Platform Operator and equivalent-exchange rules.

Sources and References

• Council Directive (EU) 2021/514 of 22 March 2021 amending Directive 2011/16/EU on administrative cooperation in the field of taxation (DAC7) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021L0514
• Directive 2011/16/EU on administrative cooperation in the field of taxation (DAC), consolidated text including Annex V (due diligence, reporting and effective implementation rules for platform operators) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32011L0016
• Loi du 16 mai 2023 relative à l’échange automatique et obligatoire des informations déclarées par les Opérateurs de Plateforme, Mémorial A No. 237 du 19 mai 2023, as subsequently amended, including by the Law of 27 March 2026 https://www.legilux.public.lu/eli/etat/leg/loi/2023/05/16/a237/jo
• ACD Newsletter of 12 June 2023 on registration and declaration requirements for platform operators https://impotsdirects.public.lu/fr/archive/newsletter/2023/nl12062023.html
• OECD Model Rules for Reporting by Platform Operators with respect to Sellers in the Sharing and Gig Economy (July 2020) https://www.oecd.org/tax/exchange-of-tax-information/model-rules-for-reporting-by-platform-operators-with-respect-to-sellers-in-the-sharing-and-gig-economy.htm
• OECD Digital Platform Information (DPI) XML Schema and User Guide https://www.oecd.org/en/publications/model-rules-for-reporting-by-digital-platform-operators-xml-schema_dd9c663f-en.html
• ACD Electronic Exchanges section (DAC7 technical documentation and MyGuichet filing portal) https://impotsdirects.public.lu/fr/echanges_electroniques.html

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.