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

Last updated: April 2026

If you operate a digital platform in Luxembourg and have not yet registered with the Administration des Contributions Directes, you are already in breach. The first DAC7 report covered calendar year 2023 and was due on 31 January 2024. The second covered 2024 and was due on 31 January 2025. The third is already accumulating. Most platform operators in financial services have this under control. Many in adjacent sectors do not, and the penalties are not symbolic.

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, not the sellers themselves.

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” as any software, including a website, application, or part thereof, that allows sellers to connect with other users to carry out relevant activities. It must include an arrangement for the collection and payment of consideration in respect of those activities. A bare listing site that never touches the money falls outside the definition. A marketplace that processes payments, or connects buyers and sellers directly, almost certainly falls within it.

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

EU Platforms and Foreign Platforms

The first category is any platform operator that is tax-resident in Luxembourg, incorporated under Luxembourg law, or has its place of effective management or a permanent establishment in Luxembourg. These are the straightforward cases.

The second category catches foreign platforms with no EU nexus that nevertheless facilitate relevant activities for sellers resident in an EU Member State, or facilitate the rental of immovable property located in an EU Member State. A platform incorporated in Singapore that allows Luxembourg residents to rent out their apartments is a Reporting Platform Operator for DAC7 purposes. The EU does not limit its reach to EU-domiciled entities.

A Reporting Platform Operator that is already registered and reporting in another EU Member State does not need to register again in Luxembourg. It must, however, notify the ACD that it has chosen to register elsewhere. The notification requirement is separate from the reporting obligation. Missing it is a separate compliance failure.

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. A pure payment processor is not a platform operator. A pure ad network is not a platform operator. The key test is whether the software facilitates the activity itself, not just adjacent services. In practice, this line is blurrier than the drafters intended, particularly for platforms that process payments and facilitate introductions simultaneously.

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 was explicitly excluded from the scope of DAC7 during the legislative process. If your platform only facilitates crowdfunding activities, it does not fall within the reporting obligation under this regime.

The personal services category is deliberately broad. It covers freelance work, delivery services, home cleaning, tutoring, and anything else that involves an individual performing a task for a user who found them through the platform. If the platform connects the parties and collects the payment, it is almost certainly within scope for personal services.

Immovable property rental includes not just residential lettings but also commercial rentals, parking spaces, and storage units, where those are facilitated via a platform with consideration paid through it. Short-term rental platforms have been the most scrutinised category since the directive was first published.

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. Governmental entities are automatically excluded.

For goods sellers specifically, a threshold applies. A seller of goods is excluded from reporting if, during the reporting period, the platform facilitated fewer than 30 transactions for that seller and the total consideration paid was less than EUR 2,000. Both conditions must be satisfied for the exclusion to apply. If either threshold is breached, the seller becomes reportable for the full year’s activity.

There is no equivalent threshold for personal services, property rental, or transport rental. A single rental transaction for EUR 100 generates a reporting obligation for that seller. I find this asymmetry genuinely difficult to explain to platform clients encountering DAC7 for the first time. The goods threshold exists because the directive was designed to catch commercial sellers on marketplaces, not occasional private sales. For services and rentals, the policy view is that any platform-facilitated income is relevant.

Entities that are listed companies or their subsidiaries are also excluded from reporting, provided the platform can establish that status. In practice, most platforms deal predominantly with individuals, so the listed-entity exclusion rarely comes up.

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 individual sellers, the required data set is: full name, primary address, Tax Identification Number (TIN) and jurisdiction of issuance, date of birth, VAT identification number (if issued), and financial account identifier (typically an IBAN or equivalent). For entity sellers, substitute the legal name, registered address, TIN, VAT number, registration number, and any permanent establishment in an EU Member State.

In addition to seller identity data, the platform must collect transaction-level data for each reportable seller. This includes: consideration paid or credited per quarter, fees and commissions withheld per quarter, number of relevant activities performed per quarter, and for immovable property rentals, the address and cadastral number (where available) of each listed property and the number of days it was rented during the reporting period.

Quarterly granularity matters. The XML schema requires quarterly breakdowns, not annual totals. If your platform only stores annual aggregates, you need to fix your data architecture before the next filing cycle, not after.

Verification Requirements

Collecting the data is only the first step. The platform must verify that the information is reliable, using all information and documents available in its records, plus any electronic TIN validation service made available by an EU Member State or the EU itself. If the platform has reason to believe that information may be inaccurate, it must request the seller to correct it and provide supporting documentation, such as a valid government-issued identification document.

Self-certification by the seller is permitted as a starting point for establishing TIN and residence. But the platform cannot simply accept whatever a seller provides. Where the platform holds contradictory information (for example, a seller’s payment account is registered in Germany but the self-certification claims Luxembourg residence), it must resolve the inconsistency before treating the seller as verified.

Due Diligence Deadlines

Due diligence must be completed by 31 December of the reportable period. For sellers already registered on the platform as of 1 January 2023, the law granted an extended deadline of 31 December 2024 to complete verification. For sellers registering from 1 January 2023 onwards, the standard deadline applies: verification must be completed by 31 December of the year in which they first use the platform for a relevant activity.

What to Report

The annual report filed with the ACD must cover, for each reportable seller, the complete identity data described above, plus the quarterly consideration, fees, and transaction counts. For property rentals, the report must also include each property address and the number of rental days.

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.

Currency matters. All consideration must be reported in the currency in which it was paid and also converted to EUR at the average exchange rate for the calendar year. If your platform processes transactions in multiple currencies, you need a reliable FX conversion mechanism in your reporting system.

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 filed electronically via MyGuichet by 31 January of the year following the reportable period. The 2023 reporting year deadline was 31 January 2024. The 2024 reporting year deadline was 31 January 2025. The 2025 reporting year deadline is 31 January 2026, and so on.

The technical format is the OECD Digital Platform Information (DPI) XML Schema, version 2.03, also referred to as DPI-DAC7 XSD. This schema is standardised across EU Member States and is the same format used in Belgium, Germany, and other jurisdictions implementing DAC7. Operators filing in multiple EU countries use the same schema for each submission, with country-specific transmission mechanisms. In Luxembourg, transmission is through MyGuichet.

Validating the XML against the XSD before uploading is not optional. The ACD will reject malformed files. In my experience with similar schema-based reporting regimes, most first-year failures come from XML structure errors or missing required fields, not from incorrect data. Build the validation step into your processing pipeline before you build anything else.

Penalties for Non-Compliance

The Luxembourg DAC7 Law follows the directive’s requirement that penalties be effective, proportionate, and dissuasive. The law did not introduce a bespoke penalty regime from scratch. It uses the existing Luxembourg framework for exchange-of-information non-compliance, under which the ACD can impose fines of up to EUR 250,000 for serious breaches. This is the same ceiling that applies to CRS and DAC6 failures.

The EUR 5,000 fine applies to registration failures, declaration and reporting failures, and incomplete or inaccurate filings alike. It is not limited to registration alone. An operator that files late, files incomplete data, or fails to notify the ACD of its registration in another Member State faces the same EUR 5,000 penalty per infringement. For serious or repeated breaches, the broader penalty framework allows the ACD to impose fines up to the EUR 250,000 ceiling.

Beyond fines, the practical consequence of non-compliance is reputational. Luxembourg is a small financial centre. The ACD communicates with other supervisory and tax authorities. A platform operator that is flagged for DAC7 non-compliance may find that flag appearing in contexts well beyond the original reporting obligation.

Frequently Asked Questions

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

Yes. A foreign platform that facilitates relevant activities for sellers resident in an EU Member State, or facilitates rental of immovable property located in an EU Member State, is a Reporting Platform Operator under DAC7. It must register in one EU Member State of its choice and file annual reports with that authority. It may choose Luxembourg as its Member State of registration, in which case it files with the ACD.

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

No, not a separate full report. A Reporting Platform Operator registered and reporting in another EU Member State must notify the ACD that it has chosen to register elsewhere, but it does not file a second DAC7 report with Luxembourg. The notification is a separate administrative step from the substantive report.

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 exclusion is assessed on an annual basis, not at the point the thresholds are met. If a goods seller crosses either threshold (30 transactions or EUR 2,000 in total consideration) at any point during the year, they become reportable for the full year. You need to monitor both metrics throughout the year and only apply the exclusion at year-end when you know the full-year picture.

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

If a seller cannot or will not provide a TIN, the platform must make two requests. If the TIN is still not provided within 60 days of the second request, the platform must close the seller’s account or withhold payments until the information is provided. You must still report the seller to the ACD with whatever data you hold, noting the missing TIN. In practice, most platforms close accounts rather than hold payments, as the operational and legal risks of withholding funds are greater.

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

The platform must use all available information, including primary address in records, TIN jurisdiction, and any electronic identification services provided by EU Member States. If the platform has reason to believe a seller claiming non-EU residence is actually EU-resident (for example, their payment account is in France), it must treat the seller as potentially reportable and apply additional verification steps. The verification obligation sits with the platform, not the seller.

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

No. There is no minimum threshold for personal services, property rental, or transport rental. A single transaction for any amount makes that seller reportable for the year. Only goods sellers benefit from the EUR 2,000 / 30-transaction exclusion.

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

Yes. Platform operators regularly use specialist compliance vendors or tax advisers to prepare and submit the DAC7 XML report. The operator remains the responsible party for the accuracy and timeliness of the filing. Vendor errors are the operator’s problem, not a defence against ACD sanctions.

Related Articles

• CARF Crypto Tax Reporting – covers the OECD Crypto-Asset Reporting Framework, which extends DAC7-style automatic exchange to crypto-asset service providers and is being transposed via DAC8 in Luxembourg.
• CESOP Reporting Explained – covers the Central Electronic System of Payment Information, the parallel EU payments reporting regime that requires payment service providers to report cross-border transactions to tax authorities. Different scope from DAC7 but similar automatic exchange mechanics.
• AML Reporting Luxembourg – DAC7 data flows often intersect with AML/KYC processes: the seller identification procedures required under DAC7 frequently draw on the same data collected for anti-money laundering customer due diligence.

Key Takeaways

• DAC7 has applied since 1 January 2023. Luxembourg transposed it through the Law of 16 May 2023. The first report (for 2023) was due on 31 January 2024.
• Any platform that connects sellers with buyers for relevant activities and handles the consideration (payments) is likely a Reporting Platform Operator, regardless of where it is incorporated.
• Relevant activities are: immovable property rental, personal services, goods sales, and transport rental. Crowdfunding was explicitly excluded. There is no minimum threshold for services and rental; the EUR 2,000 / 30-transaction goods exclusion is the only carve-out for casual activity.
• Due diligence must be completed by 31 December of each reporting period. For sellers active before 1 January 2023, the verification deadline was extended to 31 December 2024.
• Reports are filed annually via MyGuichet in OECD DPI XML Schema v2.03 format. Validate against the XSD before uploading. The ACD rejects malformed files.
• Registration on MyGuichet is mandatory. Platforms active since 1 January 2023 should already be registered. New operators must register no later than the date they begin operating.
• Penalties for non-compliance can reach EUR 250,000. The EUR 5,000 fine for registration failures is a floor, not a ceiling for the full penalty exposure.
• Foreign platforms with Luxembourg-resident sellers or Luxembourg-located properties are within scope. DAC7 is not limited to EU-incorporated entities.

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) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32011L0016
• Loi du 16 mai 2023 relative a l’echange automatique et obligatoire des informations declarees par les Operateurs de Plateforme, Mémorial A No. 237 du 19 mai 2023 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.