Compliance

Navigating DAC Recast: What Changed and What Businesses Must Do

The EU’s DAC Recast proposal introduces major simplifications—from higher thresholds for small sellers to single notifications for major reporting regimes—requiring swift action from applicable entities.

By NomadicTax Research Team • 5-8 min read • September 10, 2026

## What is the DAC Recast? The Recast of the Directive on Administrative Cooperation (DAC), proposed by the European Commission on **24 June 2026**, aims to consolidate and streamline former DAC directives into a more coherent framework. It builds on DAC1 through DAC9, refining various reporting obligations to make compliance simpler and reduce administrative burdens. ([taxation-customs.ec.europa.eu](https://taxation-customs.ec.europa.eu/news/european-commission-proposes-landmark-tax-simplification-package-streamline-compliance-and-boost-2026-06-24_en?utm_source=openai)) ## Key Changes Under the Proposal - **Higher reporting thresholds under DAC7**: The monetary threshold for sale-of-goods activities under digital platforms is raised to **€3,000**, and the activity threshold is removed. This removes reporting obligations for many private sellers and modest traders. ([taxation-customs.ec.europa.eu](https://taxation-customs.ec.europa.eu/document/download/a654ad8e-606b-4ad5-a8ff-3309554224d7_en?filename=Executive+Summary+of+Impact+Assessment_DAC_Proposal+for+a+Council+Directive+-+Taxation%E2%80%99.pdf&utm_source=openai)) - **Streamlined notifications for DAC4 & DAC9**: A unified notification obligation is proposed for Multinational Enterprise (MNE) groups to reduce duplication — reports will now use a common template and deadline. ([taxation-customs.ec.europa.eu](https://taxation-customs.ec.europa.eu/document/download/a654ad8e-606b-4ad5-a8ff-3309554224d7_en?filename=Executive+Summary+of+Impact+Assessment_DAC_Proposal+for+a+Council+Directive+-+Taxation%E2%80%99.pdf&utm_source=openai)) - **Exemptions and focus under DAC6 and DAC7**: Companies already under Pillar Two rules may be excluded from certain DAC6 disclosures; DAC7 will focus more on material thresholds. ([taxation-customs.ec.europa.eu](https://taxation-customs.ec.europa.eu/document/download/a654ad8e-606b-4ad5-a8ff-3309554224d7_en?filename=Executive+Summary+of+Impact+Assessment_DAC_Proposal+for+a+Council+Directive+-+Taxation%E2%80%99.pdf&utm_source=openai)) - **Improved identifiers and data completeness**: A centralized system for verifying TINs is proposed; exchanges of all income and capital categories (except life insurance) under DAC1 are to be included automatically. ([taxation-customs.ec.europa.eu](https://taxation-customs.ec.europa.eu/document/download/a654ad8e-606b-4ad5-a8ff-3309554224d7_en?filename=Executive+Summary+of+Impact+Assessment_DAC_Proposal+for+a+Council+Directive+-+Taxation%E2%80%99.pdf&utm_source=openai)) ## Who Is Affected? - **Digital platforms** and individual sellers with sales below €3,000 may see reduced reporting. Private sellers will have much lighter obligations. ([taxation-customs.ec.europa.eu](https://taxation-customs.ec.europa.eu/document/download/a654ad8e-606b-4ad5-a8ff-3309554224d7_en?filename=Executive+Summary+of+Impact+Assessment_DAC_Proposal+for+a+Council+Directive+-+Taxation%E2%80%99.pdf&utm_source=openai)) - **MNE groups** and companies operating in multiple jurisdictions must align their reporting under DAC4, DAC9, and Pillar Two. We'll see fewer duplicate notifications. ([taxation-customs.ec.europa.eu](https://taxation-customs.ec.europa.eu/document/download/a654ad8e-606b-4ad5-a8ff-3309554224d7_en?filename=Executive+Summary+of+Impact+Assessment_DAC_Proposal+for+a+Council+Directive+-+Taxation%E2%80%99.pdf&utm_source=openai)) - **Businesses dealing with crypto-assets** continue under DAC8 and associated formats. These remain required from 2026 onward. ([taxation-customs.ec.europa.eu](https://taxation-customs.ec.europa.eu/taxation/tax-transparency-cooperation/administrative-co-operation-and-mutual-assistance/directive-administrative-cooperation-dac/dac8_en?utm_source=openai)) ## Actionable Steps & Best Practices 1. **Assess your current disclosure obligations** under DAC6, DAC7, DAC4, DAC9, and Pillar Two. Determine whether exemptions or higher thresholds under the recast will apply. 2. **Upgrade data infrastructure** to collect and verify TINs correctly, handle unified templates, and capture all categories of income under DAC1. 3. **Monitor legislation** for when DAC Recast is formally adopted—until then, existing DAC rules and implementing regulations remain in force. 4. **Train staff & advisors** on interpreting hallmarks in DAC6 and changes to thresholds, to avoid unintended non-compliance. ## Example Scenario A small online seller in Spain sells used goods via a marketplace and earns €2,500 in a fiscal year. Under current DAC7 rules, they may need to report. Under the Proposal, with the €3,000 threshold and removal of some DAC7 burden, they would likely be exempt. Meanwhile, a multinational with subsidiaries in multiple Member States now will prepare combined notifications for DAC4/DAC9, reducing duplication and cost. ## Why This Matters Now The proposal is part of the Commission’s broader **tax simplification package**, estimated to save businesses around **€7.9 billion** yearly in compliance costs. With implementation likely following adoption by the European Parliament and Council, companies should prepare for transition. ([taxation-customs.ec.europa.eu](https://taxation-customs.ec.europa.eu/news/european-commission-proposes-landmark-tax-simplification-package-streamline-compliance-and-boost-2026-06-24_en?utm_source=openai))