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DAC7 platform and seller scope test

The “under 30 sales and under €2,000” exclusion is the most quoted line in DAC7 and the most widely misapplied. It covers goods only. For services, property rental and transport rental there is no floor at all — one booking is reportable. This tests the platform and the seller separately.

Directive (EU) 2021/514 · 4 relevant activities · 4 seller exclusions · extraterritorial · nothing stored

Test scope

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Part 1 asks whether you are a reporting platform operator. Part 2 asks whether one particular seller is reportable. Both must be satisfied before you report that seller.

Part 1 — Are you a reporting platform operator?

Directive (EU) 2021/514

A platform is any software, website or application allowing sellers to connect to users to carry out a relevant activity.

Does your software connect sellers to users to carry out a relevant activity?The four relevant activities are the sale of goods, rental of immovable property, personal services, and rental of any mode of transport.
Do you do more than only process payments, only list or advertise, or only redirect users elsewhere?Software limited to any of those three is carved out of the platform definition. Answer no if that describes you.
Do you facilitate activities by EU-resident sellers, or rental of property located in the EU?DAC7 reaches platforms established outside the Union. A non-EU operator with EU-resident sellers must register in a single member state and report through it.

Part 2 — Is this seller reportable?

Annex V · excluded sellers

A seller who performed at least one relevant activity in the period is reportable unless an exclusion applies.

Which relevant activity does this seller carry out?This decides whether any de minimis exists at all.
Relevant activities facilitated for this seller in the periodThe exclusion needs fewer than 30 activities and consideration of no more than €2,000. Both conditions must hold; crossing either makes the seller reportable.
sales € total
Is the seller a governmental entity?
Is the seller a listed entity, or an entity more than 50% affiliated to one?
Did the platform facilitate more than 2,000 rentals for property listings at the same street address?The high-volume property exclusion, aimed at hotel chains and tour operators.
What this means: an indicative scope result for one platform and one seller. Member states have implemented DAC7 with their own registration mechanics, penalty regimes and in some cases extended deadlines, so the local rules govern. Due diligence must be completed by 31 December and reporting made by 31 January following the calendar year. This is not tax advice.

Twenty-two data points, per seller, per year. The DAC7 module takes seller and transaction data, applies due diligence outcomes and the exclusions, validates and produces the reporting file — with a free tier to start.

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The misreading

Where the de minimis does and does not apply

Several large marketplaces present the 30-sales rule in their help pages as a general DAC7 threshold. It is not.

Goods

A narrow floor, both limbs

Excluded only where the platform facilitated fewer than 30 sales of goods and total consideration did not exceed €2,000. Crossing either one makes the seller reportable.

Services, rentals

No floor at all

A landlord with two bookings is reportable. A consultant with one client is reportable. Platforms in these categories cannot filter their seller base down before reporting.

High volume

An exclusion at the top

Sellers with more than 2,000 rentals against listings at the same street address are excluded — the hotel chain carve-out. It works in the opposite direction to the de minimis.

Rules reviewed 21 August 2026 · Council Directive (EU) 2021/514 amending Directive 2011/16/EU · Annex V

Scope

What this test does

It doesTest both halves

  • Applies the platform definition, including the payment-only, listing-only and redirect-only carve-outs.
  • Accounts for the extraterritorial reach to non-EU operators with EU-resident sellers.
  • Applies the de minimis to goods only, and requires both limbs.
  • Applies the governmental, listed and high-volume property exclusions.
  • States plainly where no de minimis exists for the activity in question.
  • Separates a clear result from one resting on unresolved questions.

It does notApply local implementation

  • Reflect any member state’s registration mechanics, deadlines or penalty regime.
  • Determine seller residence, or which member state you report through.
  • Handle due diligence, TIN collection or verification.
  • Decide whether a digital product is a good or a service.
  • Cover DAC8, which extends the regime to crypto-assets separately.
  • Produce anything you can file, or constitute tax advice.

Reporting sellers means reporting TINs

Seller tax identification numbers are among the data points collected and reported. A malformed TIN is a validation failure at submission.

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Questions

About DAC7 scope

Which activities are in scope?

Four: the sale of goods, rental of immovable property, personal services, and rental of any mode of transport. A platform facilitating any of them for EU-resident sellers, or rental of EU-located property, is within scope.

Does the 30-sales rule apply to my services marketplace?

No. The de minimis applies to sellers of goods and to nobody else. There is no floor for personal services, property rental or transport rental, so a seller with a single transaction in those categories is reportable. This is the most common misunderstanding in DAC7, and several large marketplaces state it incorrectly.

Do both limbs of the goods exclusion have to be met?

Yes. The seller must have had fewer than 30 relevant activities by way of the sale of goods and total consideration not exceeding €2,000 during the reporting period. Crossing either threshold makes the seller reportable.

We are not established in the EU. Does it still apply?

It can. DAC7 applies to platforms established outside the Union where they facilitate relevant activities by EU-resident sellers or the rental of property located in the EU. Non-EU operators register in a single member state and report through that state.

Which platforms are carved out?

Software limited to processing payments, to listing or advertising, or to redirecting or transferring users to another platform. If your software does only those things it falls outside the platform definition.

When is the deadline?

Due diligence must be completed by 31 December, with reporting by 31 January of the year following the calendar year in which the reportable seller was identified. Some member states have applied extended deadlines, so confirm locally.

Do you store my answers?

No. Everything is held in the page and discarded when you close or reload it.

The exclusion is narrower than the internet thinks.

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