EU Tax Simplification Package 2026: What the DAC Recast Means for DAC6, DAC7 and CESOP Reporting

ByOfficer

Last updated: June 2026

The first thing a reporting team does wrong with the EU tax simplification package is treat it as a deadline. It is not. On 24 June 2026 the European Commission published two proposals, a Direct Taxation Omnibus and a recast of the Directive on Administrative Cooperation, and a proposal changes nothing about what you file next quarter. The risk runs the other way. Teams read the headline figure of EUR 7.9 billion in promised savings, assume their DAC6 or DAC7 obligations are about to shrink, and quietly deprioritise the build work that current law still requires. Then the recast slips, as unanimity files often do, and they are exposed on the reporting they stopped maintaining.

This article is about what the package actually proposes for the reporting obligations financial institutions and platform operators already carry: DAC6 mandatory disclosure, DAC7 platform reporting, CESOP payment data, and DAC8 crypto-asset reporting. Two of those four are touched by the recast. Two are not, and getting that distinction right is the whole job here. The EU tax simplification package is a planning input for 2027 and beyond, not an instruction for your next filing window.

Related reading: our DAC6 mandatory disclosure guide sets out the hallmark structure and intermediary scope that the recast would amend.

What the Commission actually proposed on 24 June 2026

The package is two distinct legislative proposals, and they move at different speeds. The Direct Taxation Omnibus reworks substantive tax rules: a full withholding tax exemption for cross-border dividends, interest and royalties between associated EU companies, a simplified interest limitation rule under Article 4 of the Anti-Tax Avoidance Directive, and removal of duplicate computations between controlled foreign company rules and the Pillar Two minimum tax under Directive (EU) 2022/2523. The Omnibus matters for tax departments. It does not directly change the cross-border reporting returns this site covers, so it sits outside the rest of this analysis.

The recast of the Directive on Administrative Cooperation is the proposal that touches reporting. It consolidates Council Directive 2011/16/EU and its eight successive amendments into a single instrument, and it trims several reporting obligations in the process. The Commission estimates the recast alone removes over EUR 1 billion in annual compliance cost. Both proposals require unanimous Council adoption under Article 115 TFEU, and both then go to the European Parliament for consultation. That legal base is the reason a timeline matters less than reporting teams expect. One Member State can hold the file.

The Commission and the incoming Irish Council presidency have signalled they hope to agree the DAC recast by the end of 2026. That is an aspiration, not a transposition date. Even if political agreement is reached in 2026, a recast directive would still need adoption, Official Journal publication and Member State transposition before national portals change. The proposal contains bracketed implementation dates, with [31 December 2027] transposition and [1 January 2028] application appearing in the proposal for certain provisions, but those dates are proposal text only and can change during Council negotiations. Anyone telling a DAC6 or DAC7 team that obligations drop in early 2027 is reading a press release as if it were an Official Journal citation.

DAC6: a narrower regime, but the hallmarks still bite

DAC6 is Council Directive (EU) 2018/822, which amended Directive 2011/16/EU and inserted the mandatory disclosure regime for reportable cross-border arrangements. Member States have applied DAC6 since 1 July 2020. Current Article 8ab(1) requires reporting within 30 days from the day after the arrangement is made available, is ready for implementation, or the first step is implemented, whichever occurs first, and current Article 8ab(2) requires three-month updates for marketable arrangements. The recast would change this. It would extend the filing period from 30 to 90 days, calculated from the first step of implementation rather than from the made-available or ready-for-implementation triggers. Those changes would apply only if the recast is adopted and transposed.

The recast narrows DAC6 scope in several specific ways. It would exclude companies within the scope of the Pillar Two Directive from DAC6 reporting, but the carve-out is conditional on minimum-tax coverage and sets conditions as detailed in the proposal text. The Commission estimates the Pillar Two DAC6 exclusion would save about EUR 300 million for around 3,000 groups. For companies outside Pillar Two, the recast would remove Category A generic hallmarks and reduce DAC6 disclosures by about 35 percent, with about EUR 40 million in annual savings. It would also require a Council implementing act to develop the substance criteria in Hallmark D2.

Here is where teams misread the proposal. A 35 percent cut in volume is not a 35 percent cut in obligation. The hallmark architecture in Annex IV does not survive intact. The recast would delete Category A generic hallmarks, retain other hallmark categories subject to the revised Annex IV, issue guidance on the Main Benefit Test for the remaining hallmarks subject to that test, and require a Council implementing act to develop the substance criteria in Hallmark D2. An arrangement that fails the main benefit test today fails it after the recast. The proposal removes a defined band of Category A hallmarks and a defined population of Pillar Two groups. It does not soften the test you apply to everything that remains.

The practical trap is the Pillar Two carve-out. The proposal does not turn on size alone, but Pillar Two scope is defined around groups with consolidated annual revenue of at least EUR 750 million. The DAC6 exclusion is conditional on minimum-tax coverage and sets conditions as detailed in the proposal text. Treat the carve-out as a future rules-engine condition, not as permission to switch off live DAC6 controls before adoption and transposition.

DAC7: the threshold moves, the platform plumbing stays

DAC7 is Council Directive (EU) 2021/514. It inserted Article 8ac and Annex V into Directive 2011/16/EU and made platform operators collect, verify and report seller income, with Member States applying the rules from 1 January 2023. The reporting cadence is fixed and the recast does not touch it: a Reporting Platform Operator files by 31 January of the year following the calendar year in which a seller is identified as reportable, having completed due diligence on each reportable seller by 31 December of the reportable period. Foreign platform operators register once in a single Member State, and that single-registration mechanism in Section IV of Annex V is unchanged by the proposal.

The proposed change is to the threshold for online sales of goods. The Commission would raise it, removing reporting obligations for more than 10 million private sellers, largely of second-hand goods, with estimated platform savings of EUR 678 million. This is the circular-economy angle: a casual seller offloading used items should not generate a tax report, and the threshold lift is meant to draw that line higher.

What this is not is a holiday from the rest of DAC7. The other reporting obligations in Annex V all sit outside the online-sales-of-goods threshold: immovable-property rental reporting with its quarterly consideration and property-listing detail, the financial account identifier requirement, the active-seller due diligence option under Section II.G, and the account-closure rule for sellers who do not provide due diligence information after two reminders (applied no earlier than 60 days after the initial request). A platform that runs accommodation rentals or personal services is barely affected by a goods threshold. The common error here is a product team hearing “DAC7 threshold raised” and assuming the platform’s whole reporting population shrinks, when the lift only reaches one relevant activity. Map the change to the specific activity it touches before you re-scope a single seller.

There is a build consequence worth stating plainly. The threshold lift, if adopted, changes which sellers cross into reportable status, which means it changes your due-diligence triggering logic and your year-end seller classification, not just your output file. That is a rules-engine change, not a report-template change, and it is the kind of detail that does not surface until you read the recast text rather than the savings estimate.

CESOP: a separate legal instrument the package leaves untouched

CESOP sits in the VAT Directive framework under Council Directive (EU) 2020/284, not in the direct-taxation administrative-cooperation directive being recast. The Commission press release and the proposal text both leave CESOP untouched. For payment service providers, the obligation is unchanged: since 1 January 2024, the four categories of PSP in Article 243a, credit institutions, e-money institutions, payment institutions and post-office giro institutions, must monitor payees who receive more than 25 cross-border payments per quarter and transmit the Article 243d data set quarterly, with deadlines at the end of April, July, October and January following each reporting quarter.

This is the cleanest place to correct a recurring confusion. The recast does eliminate a duplicate-notification burden worth over EUR 260 million a year, but that figure refers to a single notification obligation for country-by-country reporting and the central filing of top-up tax information returns under Pillar Two. It is not a CESOP measure and it is not a payments measure. A PSP reporting team that reads “EUR 260 million from removing duplicate notifications” and expects relief in its CESOP filing is chasing a saving that lives in a different directive entirely. Keep the CESOP build and the CESOP calendar exactly where they are.

One operational point for PSPs that also run platforms or sit inside larger groups. Because CESOP and DAC are separate legal instruments with separate portals and separate deadlines, a simplification to DAC reporting does not consolidate your CESOP submission. The cross-border-payments file and the platform or arrangement files remain distinct returns. Our CESOP reporting walkthrough sets out the quarterly mechanics that this package leaves untouched.

DAC8: untouched, in force, and the easiest thing to drop by accident

DAC8 is Council Directive (EU) 2023/2226, the crypto-asset reporting amendment built on the OECD Crypto-Asset Reporting Framework. It entered into application on 1 January 2026, with Member States required to transpose it by 31 December 2025. The simplification package does not amend it. Reporting Crypto-Asset Service Providers should already be collecting data on reportable crypto-asset transactions of EU-resident users from 1 January 2026, with the first exchanges relating to the 2026 reporting year due by 30 September 2027.

The risk with DAC8 in this period is purely one of attention. A crypto-asset service provider standing up its first CARF-aligned reporting cycle, while the trade press runs daily coverage of a “DAC simplification,” can reasonably but wrongly conclude that its own obligation is being eased. It is not. DAC8 sits inside the same Directive 2011/16/EU that the recast consolidates, so it will be carried into the single recast instrument, but consolidation into a recast is a renumbering and tidying exercise, not a repeal. A provider that pauses its 2026 data collection because “the DAC is being simplified” has confused codification with deregulation. The collect-from-1-January-2026 obligation stands.

How to use this package without getting ahead of the law

The honest reading of 24 June 2026 is that reporting teams gained a planning document, not a rule change. The work it justifies is mapping and scenario analysis, run in parallel with business as usual. For DAC6, that means identifying which of your reportable arrangements would fall away under a Pillar Two carve-out and a Category A hallmark removal, so you can size the future change without acting on it. For DAC7, it means tagging which sellers a higher online-goods threshold would move out of scope, by relevant activity, so the eventual rules-engine change is already specified.

The discipline is to keep two registers. One is your live obligation, which is exactly what current law requires this quarter, unchanged. The other is your proposed-change impact, which is what the recast would do if adopted in something like its current form. The mistake that produces enforcement exposure is letting the second register bleed into the first, dialling down a control because a saving has been announced. Announced savings are not in force. The DAC recast is a proposal subject to unanimity, and until it is adopted, published in the Official Journal and transposed, the regulation requires you to file as you file today.

If you brief leadership on this package, the one sentence that keeps the team safe is that the obligations do not change until the recast is adopted and transposed, and the timeline for that is an aspiration to agree by end-2026, not a date you can build against. Everything else is preparation.

Frequently Asked Questions

Does the EU tax simplification package change my DAC6 filing obligations right now?

No. The package published on 24 June 2026 is a set of proposals. Until the DAC recast is adopted, published in the Official Journal and transposed by Member States, the current DAC6 regime under Directive (EU) 2018/822 applies unchanged, including the current 30-day reporting trigger in Article 8ab(1). The recast proposal itself would change that timing to a 90-day period from the first step of implementation, but that proposal is not yet in force.

Will Pillar Two groups stop reporting under DAC6?

The recast proposes to exclude companies within the scope of the Pillar Two Directive from DAC6 reporting, an estimated saving of around EUR 300 million for roughly 3,000 groups. The carve-out is conditional on minimum-tax coverage and sets conditions as detailed in the proposal text. This is a proposal, and the carve-out should be scoped carefully as a future rules-engine condition if and when it is adopted.

What changes for DAC7 platform operators?

The recast proposes raising the threshold for online sales of goods, which the Commission estimates would remove reporting for more than 10 million private sellers of mostly second-hand goods, with EUR 678 million in platform savings. The 31 January reporting deadline, the due-diligence rules in Annex V, and reporting for other relevant activities such as immovable-property rental are not changed by the proposal.

Does the package affect CESOP payment reporting?

No. CESOP sits under the VAT Directive framework in Directive (EU) 2020/284, not in the administrative-cooperation directive being recast. PSPs in the four Article 243a categories continue to report payees receiving more than 25 cross-border payments per quarter, with quarterly deadlines at the end of April, July, October and January, exactly as before.

Is the EUR 260 million duplicate-notification saving a CESOP measure?

No. That figure refers to a single notification obligation the recast introduces for country-by-country reporting and the central filing of top-up tax information returns under Pillar Two. It is unrelated to CESOP and to payments reporting.

Does the package change DAC8 crypto-asset reporting?

No. DAC8 under Directive (EU) 2023/2226 entered into application on 1 January 2026 and is not amended by the package. Reporting Crypto-Asset Service Providers should be collecting data on EU-resident users from 1 January 2026, with first exchanges for the 2026 reporting year due by 30 September 2027.

When could the DAC recast actually take effect?

The proposal contains bracketed implementation dates for certain provisions, with [31 December 2027] transposition and [1 January 2028] application appearing in the text, but those dates are proposal text only and can change during Council negotiations. Because adoption needs unanimity under Article 115 TFEU, the timeline is uncertain; the Commission and the incoming Irish Council presidency have signalled a hope to agree by end-2026, but that is an aspiration, not a transposition date.

What should my reporting team do between now and adoption?

Keep filing under current law without interruption, and run a separate impact-mapping exercise to identify which arrangements or sellers the proposed changes would move out of scope. Do not reduce any live control on the basis of an announced saving that is not yet in force.

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Key Takeaways

  • The EU tax simplification package of 24 June 2026 is two proposals, a Direct Taxation Omnibus and a DAC recast. It changes no reporting obligation until adopted and transposed.
  • The DAC recast would narrow DAC6 by carving out Pillar Two groups (around EUR 300 million, conditional on minimum-tax coverage) and removing Category A generic hallmarks (roughly a 35 percent volume cut, EUR 40 million). It would also extend the DAC6 filing period from 30 to 90 days and shift the trigger to the first step of implementation. None of these changes apply until the recast is adopted and transposed.
  • DAC7 would gain a higher online-sales-of-goods threshold, removing reporting for more than 10 million private sellers and saving platforms an estimated EUR 678 million. Other relevant activities and the 31 January deadline are unchanged.
  • CESOP is not in the package. PSPs keep reporting payees above 25 cross-border payments per quarter under Directive (EU) 2020/284, on the same quarterly calendar.
  • The EUR 260 million duplicate-notification saving relates to country-by-country and Pillar Two top-up tax filings, not to CESOP or payments.
  • DAC8 crypto-asset reporting under Directive (EU) 2023/2226 is untouched and in force; data collection from 1 January 2026 and first exchanges by 30 September 2027 still apply.
  • Adoption requires unanimity under Article 115 TFEU. The proposal carries bracketed implementation dates (including [31 December 2027] transposition and [1 January 2028] application for certain provisions), but those dates are proposal text only. The end-2026 agreement target is an aspiration, with transposition still to follow.

Sources and References

  • European Commission, “European Commission proposes landmark tax simplification package to streamline compliance and boost competitiveness” (24 June 2026): taxation-customs.ec.europa.eu
  • Council Directive (EU) 2018/822 of 25 May 2018 (DAC6), amending Directive 2011/16/EU as regards reportable cross-border arrangements: EUR-Lex CELEX 32018L0822
  • Council Directive (EU) 2021/514 of 22 March 2021 (DAC7), amending Directive 2011/16/EU as regards platform operators: EUR-Lex CELEX 32021L0514
  • Council Directive (EU) 2020/284 of 18 February 2020 (CESOP), amending Directive 2006/112/EC as regards payment service provider record-keeping: EUR-Lex CELEX 32020L0284
  • Council Directive (EU) 2023/2226 of 17 October 2023 (DAC8), amending Directive 2011/16/EU as regards crypto-asset reporting: EUR-Lex CELEX 32023L2226
  • European Commission, DAC8 information page (entry into application 1 January 2026, first exchanges by 30 September 2027): taxation-customs.ec.europa.eu/dac8
  • European Commission, CESOP guidelines for payment service providers (Article 243a to 243d, more than 25 cross-border payments per quarter): taxation-customs.ec.europa.eu/cesop

Reading a proposal as a proposal

The DAC recast is the most reporting-relevant tax simplification the Commission has put forward in years, and it would genuinely shrink the DAC6 and DAC7 footprint for in-scope groups and platforms. The error it invites is acting early. A proposal that needs unanimous Council agreement, a recast that carries bracketed application dates subject to change in negotiations, and a saving headline measured in billions all push a reporting team toward switching off work that current law still requires. The teams that come out of this period clean will be the ones that mapped the change, kept filing under today’s rules, and waited for an Official Journal citation before touching a single control.

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.

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