The deadline for meeting the obligations under the DAC7 directive and the Polish regulations implementing it is fast approaching.
Online platform operators must fulfil their reporting obligations by 31 January 2026 at the latest with regard to 2025 data.
For many, this is the final opportunity not only to prepare the required information, but also to verify whether DAC7 obligations apply to them and, if so, to what extent.
DAC7: What needs to be done before 31 January?
The DAC7 directive imposes two key information obligations on platform operators:
- Providing summary information on reportable sellers to the Head of the National Revenue Administration (KAS)
- Providing each seller with information collected about them that is subject to reporting
In practice, these obligations require extensive data to be collected and verified in advance, as well as the correct classification of sellers and transactions.
Why is DAC7 a real challenge?
The DAC7 rules are technical, multi-layered and riddled with exceptions. This means that:
- Not every platform operator is subject to reporting obligations
- There are a number of exemptions and exclusions that can significantly reduce or even eliminate the need for reporting.
- Incorrect assessment of the status of operators or sellers can lead to obligations not being fulfilled correctly
In addition, platform operators must exercise due diligence. This involves developing and implementing internal procedures, verifying seller information and adapting processes and systems (including those relating to IT) to comply with DAC7 requirements.
Procedures, sanctions and corrections: key conclusions
If fulfilling DAC7 obligations is overly burdensome or if there is a risk of missing the deadline, it is clear that internal DAC7 procedures need to be implemented or adjusted.
Well-designed procedures can reduce the risk of errors, streamline the collection and verification of data, and reduce the organisational burden in subsequent years.
Failure to comply with DAC7 obligations or the provision of incorrect data may result in a fine of up to PLN 1,000,000.
However, the regulations permit the correction of summary information provided to the Head of the National Revenue Administration, even after the deadline, as long as it remains consistent with the information provided to sellers.
How can we help?
We provide a practical approach tailored to your business model, helping you with every stage of DAC7 compliance, including:
- Verification of whether and to what extent your company is subject to reporting obligations
- Identification of possible exemptions and exclusions
- Support in preparing and submitting summary information to the Head of the National Revenue Administration
- Assistance in the correct transmission of information to sellers
- Development and implementation of due diligence procedures
- Support with correcting reports and dealing with the tax authorities
Any questions? Contact us
