Developing DAC7: 5 lessons for the workable regulation of the platform economy.

Since 2023, platforms have had to share supplier data with tax authorities. What are the implications of this legislation? How can we achieve better regulation? Researchers Ahmed Darwish and Martijn Arets share lessons.

Since 2023, platform operators have been obliged to collect and share vendor data with the tax authorities. By imposing reporting obligations, this so-called Directive on Administrative Cooperation (DAC7) aimed to ensure more transparency regarding the income earned through digital platforms and aid tax authorities in countering fraud.

Does the legislation do what the Council of the European Union intended it to do? How can it be improved? As part of the Platform Economy Research Group at The Hague University of Applied Sciences, we, Ahmed Darwish and Martijn Arets, took a closer look at the development and effects of the legislation. While, at first glance, the legislation seems logical and practical, there are a number of questions and concerns raised by entrepreneurs. What can policymakers learn from this?

Five lessons for regulation in the platform economy:

1. Provide clear guidelines
2. Offer support
3. Consult stakeholders in advance
4. Implement regulations based on company size
5. Make sure government institutions are ready for the new legislation

What is DAC7?

DAC7 is an EU directive aimed at improving tax transparency on income via digital platforms. By 1 January 2023, all European Union member states were required to incorporate this directive into their domestic legal frameworks (DAC7, Article 2.1). Since then, digital platforms have been obliged to identify, verify, and report the income of sellers that utilize their platforms.

The legislation applies specifically to platforms that bring together the supply and demand of products and services (DAC7, Article 1.8). They must share the details of suppliers on their platform with the tax authorities. These can be sellers of new goods (such as Bol, Amazon) and second-hand goods (such as eBay, Vinted). Platforms facilitating for booking hotels, holiday homes, and hospitality (such as Airbnb, Booking) are also covered by this legislation. It may also cover service providers, such as taxi drivers (such as Uber, Lyft), babysitters (such as Charly Cares) or food delivery (such as Thuisbezorgd, UberEats).

Any platform where sellers can offer certain services or goods to other users may be subject to the directive. As such, webshops that only sell their own products are not covered by the new legislation. It does not matter whether the platform is registered in the EU, as long as the sellers operate within the EU. The tax authorities of Member States also exchange the data gathered among themselves.

Digital platforms have access to information on markets that were previously highly fragmented. The EU is thus cleverly leveraging the immense power and information held by digital platforms. Indeed, before platforms brought supply and demand together digitally, people still traded products and services in ways that were less visible to tax authorities. Although they were, in certain cases, required to declare their income, many did not. In those cases, the tax authorities had no information. Platforms can, therefore, help governments obtain information about previously invisible highly fragmented markets (European Commission, Rationale).

Why this case study?

The idea of digital platforms sharing data with public authorities seems simple and logical. In practice, however, implementation proves more complicated. There are many differences between national governments and digital platforms. Although the platform economy consists mainly of small companies, legislation seems tailored at larger companies that have more resources to store and process data. Indeed, much of the platform market is an SME market. According to the ‘Monitor online platforms 2023’ (CBS, 2023), 64.2 per cent of the 1,600 Dutch platform companies have two or fewer employees. Only 5 per cent of these companies have more than 100 employees. 

We did an exploratory case study of DAC7, focusing on the Dutch context. We interviewed all sorts of stakeholders and experts, including platform operators, representatives, experts from the Tax Administration, and academics. We analyzed the directive, its implementation, and its impact on the platform economy. As a result, we produced five recommendations for future policy initiatives around the platform economy.

Benefits

The main benefits of DAC7 are:

1. Less fraud through data sharing

By sharing data, platforms and governments can work together to prevent tax fraud. DAC7 also promotes cross-border tax compliance, as some larger digital platforms operate in multiple countries. Data sharing leads to higher effectiveness and efficiency in monitoring revenues (European Commission, Rationale). By making data related to income transparent to tax authorities, they can better assess whether someone is a ‘seller’ for tax purposes or not. DAC7 applies only within the EU but promotes international cooperation with countries outside the EU, thanks to its alignment with OECD guidelines. It is important that platforms implement DAC7 properly and inform their users about the process. Since users know that their income data will be collected and shared with tax authorities, they will be more aware that they may have to pay their taxes. DAC7 thus helps not only detect fraud but also prevent it. However, success depends on the tax authorities’ ability to collect and reliably process the data.

2. Better cooperation between governments and platform operators

Technological developments are happening at a rapid pace and, as a result, policy often lags behind. Transparent cooperation between governments and the technology industry can help reduce the information gap and promote trust. In that vein, DAC7 is a step in the right direction. With their valuable data, platforms can help governments with enforcement and regulation, as long as the processes are workable and the impact on business processes and data collection proportional.

3. Improving KYC processes

DAC7 standardizes Know Your Customer (KYC) processes, since platforms must collect, verify, and report user data (such as name, address, and tax numbers) to national tax authorities in a uniform manner. This standardization reduces compliance costs, increases predictability for users, and can serve as a basis for further regulation (Vidal, 2024).

Disadvantages

The new directive has a lot of potential benefits, but it is far from perfect. Our analysis shows the main drawbacks:

1.A too broad definition, a tight timeline and a lack of guidance for platforms
The timeline of policy decisions and implementation was quite tight. For example, the Dutch Senate took a final decision on DAC7 on the 20^th of December 2022 and companies had to have already implemented it less than two weeks later (1 January 2023). Adding to the confusion, DAC7 had to be implemented at a different deadline for each member state (Trolley, 2024). Although all member states had to be ready for DAC7 at the same time, some governments took more time than others (European Commission, 2023). This was especially difficult and costly for platforms operating in multiple member states.

Many platforms found the directive’s provisions unclear, leading to uncertainty. The directive used broad and vague wording. Moreover, the definition of what a platform meant in this legislation was abstract and unclear. Some operators were forced to incur excessive compliance costs, to avoid being fined or penalized. This uncertainty and lack of clarity also affected platform suppliers, who suddenly had to share more personal data than they initially collected and did not understand why it was necessary. 

Due to the high-pressure timeframe, the Tax Administration did give platforms much time and leniency, a so-called ‘soft landing’. The tax authorities tried to keep platforms well informed and provide them with support. With the implementation phase complete, the Tax Administration is slowly moving to stricter enforcement.

2. High compliance costs and inequality
DAC7 imposes a heavy administrative burden on platform operators, a group that mainly consists of small and medium-sized enterprises (SMEs). The directive seems to be tailored for larger platforms, but the obligations also apply to smaller players. For them, the costs of data collection, storage, and reporting are high. The labor and financial costs associated with compliance hinder growth and innovation. Whereas the OECD directive included an exception for small platforms, companies with up to €1 million in turnover, the EU decided not to include this exception in DAC7 (OECD MRDP, 2020).

3. Potentially discouraging participation
Stricter reporting requirements make digital platforms less attractive to sellers. Users become reluctant, as they cannot be certain about what the Tax Administration will do with the reported data and how it will impact their tax calculation. Some users even decided to work outside the platform out of uncertainty and fear. Research shows that knowledge of DAC7 regulations lowers the willingness to work utilizing platforms, noting a chilling effect. Users get the feeling that the government is watching them closely. This leads to distrust and fear (Mol & Molho, 2024).

4. Additional collection of privacy-sensitive data
To comply with DAC7, some platforms have to request and store additional personal data from their sellers. This is most relevant for platforms that specialize in facilitating the sales of second-hand goods. They store data that is not essential to the transaction, raising several significant privacy risks.

5. Limited capacity of Tax Administrations
Finally, platform operators doubt the Tax Administration’s ability to deal with the huge amount of data. The Tax Administration indicated that the DAC7 data is a new source of information for their inspectors. The Tax Administration aims to determine how reliable the data is, before inspectors use it for enforcement. In the future, if the Tax Administration has reason to think that people are not complying with legislation, inspectors will choose other enforcement tools, such as regular inspection. In doing so, the inspector can use the DAC7 reported data to check whether the tax information reported is correct. While the Tax Administration is optimistic about their ability to analyze large datasets, platforms are more critical. Until the Tax Administration is able to deliver on the goals set out by DAC7, compliance will feel like a disproportionate burden.

Conclusion – Five lessons for better guidelines:

1. Provide clear guidelines and a realistic timeline.
The first lesson is that legislation should be accompanied by clear, consistent, and accessible guidelines. This will make it easier for small- to medium-sized entrepreneurs to comply with regulations. Many problems that platforms encountered with DAC7 stemmed from confusion and a lack of legal certainty. This confusion concerned both the reporting requirement and the tax implications. A realistic timeline for implementation also proved important.

2. Offer support
The second lesson is that start-ups and other small businesses need support to be able to comply with complex legislation. These enterprises usually do not have a legal or compliance department. As a result, they struggle to understand how legislation can affect their business and how they can comply with regulations. Targeted support can help these businesses develop strategies for compliance. The government forced platforms to invest their own time and resources to obtain legal advice, hire compliance experts, and outsource data transmission. This discouraged their investors and hindered growth. Authorities should therefore develop targeted support for SMEs, such as:

1. Simple checklists, timelines, and step-by-step instructions, such as the information page on DAC7 set up by the Dutch Tax Administration.
2. Targeted compliance support programmes and advisory services. For example, the Dutch Tax Administration held informative presentations on DAC7 via intermediary days and umbrella organisations.
3. Access to digital tools and solutions.

It is crucial to actively inform SMEs about this support. The government should also launch campaigns to inform platform users. After all, support in communication or a public information campaign can increase acceptance and awareness.

3. Consult stakeholders in advance
It is wise to engage with platform operators about new regulations as early as possible. That way, policymakers can develop legislation and guidelines that are well aligned with practice. In the case of DAC7, stakeholders did not always feel heard. The online consultation received hardly any reactions beforehand, as SME platforms were unaware of the consultation or did not have DAC7 as a priority. Large platforms felt that little was done with their feedback. An earlier consultation at the national level could add value here.

Collaboration improves the effectiveness of legislation, especially with complex business models and in unpredictable situations. It also gives policymakers insight into the processes and variables within a seemingly homogenous group of companies. Furthermore, it increases trust and transparent communication between entrepreneurs and policymakers.

4. Implement regulations based on company size
The fourth lesson is that the regulatory burden should not be disproportionate. While you can expect companies to perform KYC reviews, excessive financial and administrative burdens can discourage new investments and hinder growth. One recommendation is to apply rules proportionally based on the size of the platform. While the provisions were more suitable for larger platforms, medium and small platforms fell within the rules. 

A better approach would be a categorised structure, where reporting obligations are tailored to a company’s size or turnover. The cost and additional workload of complying with the regulations should be proportional to the size of the business. Thus, small business owners are not overburdened or unfairly disadvantaged compared to large, established competitors.

In addition, policymakers should be careful when determining the scope of legislation. For DAC7, many question whether the burden imposed outweighs the potential disadvantages.

5. Make sure government institutions are ready for the new legislation
The fifth and final lesson is that government institutions such as the Tax Administration must be ready for the new regulations in advance. The technology and team must be capable of handling and monitoring implementation. For example, platforms experienced a high barrier due to the complex reporting system. Platform companies must therefore develop a gateway in their own software that communicates directly with the Tax Administration’s systems or use intermediaries who charge between €1,300 and €1,800 a time for this (NRC, 2025). The Dutch Tax Administration now recognizes this and is working on a simpler system. Platform operators feel as though they have wasted their time and money on adapting to methods that will have to be adjusted later on. With small-scale tests being rolled out in advance, this situation could have been avoided.

Sources and thanks
We thank the experts who contributed to this research through interviews and feedback on this article. In particular, Chantal Malfeyt (Marktplaats), Joey van Angeren (Vrije Universiteit Amsterdam), Pepijn Niesten (Booka Rentals), Jasper van Schijndel (PwC), Dion Egiyan (PwC) and Juan Manuel Vázquez (UvA). We also thank Merel Hillen of The Hague University for coordination and organisation.

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