DAC Recast: from reporting obligations to data-driven tax risk

While successive amendments to DAC have significantly strengthened access to information, transparency and cooperation between tax administrations, they created a fragmented compliance environment. Businesses operating internationally often face overlapping notification requirements, multiple reporting streams and different implementation approaches across Member States.

Against this background, the European Commission published, on 24 June 2026, a proposal to recast the DAC framework as part of the broader EU Tax Simplification Package. The proposal consolidates DACs nine parts into a single legislative instrument, while introducing targeted simplifications aimed at reducing administrative burden.

Why DAC data matters

Many businesses continue to view DAC reporting as a compliance exercise. However, information filled and exchanged under the DAC framework has become a fundamental tool for tax authorities to conduct risk assessments for audits and identify inconsistencies between different tax reporting obligations.

The scale of information exchange is significant. According to the Performance Report of the National Agency for Fiscal Administration (ANAF), more than 8.5 million records were processed through Romania's Automatic Exchange of Information platform and transmitted to relevant EU tax authorities only in 2025.

Summary of DAC scope and changes introduced by the Recast initiative

DAC1 and DAC2: identifying undeclared income and assets

DAC1 and DAC2 information enables tax authorities to compare taxpayer foreign-source income and financial assets against domestic tax returns and declarations. Discrepancies between information reported by foreign institutions and information reported by taxpayers may trigger requests for clarification, voluntary compliance requests or formal investigations.

DAC3: Exchange of information on advanced cross-border tax rulings and advanced pricing agreements (APA)

DAC3 introduced the mandatory automatic exchange of information on cross-border tax rulings and APAs between EU Member States. Under DAC3, tax administrations are required to periodically share information on qualifying rulings issued to taxpayers, allowing other Member States to assess potential tax implications within their jurisdictions.

DAC4 and DAC9: Country-by-Country Reporting (CbCR) and Pillar 2 exchange of information

CbCR data is a risk assessment tool that provides tax authorities with valuable information about the multinational group’s allocation of profits, revenues, employees and assets.

Romanian Tax Authorities have already performed BEPS risk assessment review based on DAC4 information and exchanged over 10,000 CbCR reports with foreign jurisdictions in 2025[1].

Pillar Two was implemented in Romania through Law No. 431/2023, introducing a 15% global minimum effective tax rate for large multinational and domestic groups with revenues exceeding €750 million, and is subject to reporting obligations within the EU and exchange of information between Member States through DAC9.

The DAC Recast proposes a significant simplification for multinational groups by merging DAC4 and DAC9 notification obligations. Instead of multiple notifications submitted under different timelines, groups would be able to submit a single notification covering both CbCR and Pillar Two reporting with a single deadline.

DAC6: an early visibility mechanism

DAC6 was introduced to enhance tax transparency within the European Union by requiring taxpayers to disclose certain cross-border arrangements that may indicate tax avoidance or aggressive tax planning risks. Through the mandatory reporting and automatic exchange of information between Member States, DAC6 aims to provide tax authorities with an early-warning mechanism, improve risk assessment capabilities, strengthen administrative cooperation and to prevent the use of structures that could erode national tax bases, while not implying that a reportable arrangement is necessarily unlawful or abusive.

The proposal narrows the scope of reportable arrangements, removes Category A hallmarks[2], introduces a carve-out for groups within the scope of Pillar Two and extends reporting deadlines from 30 to 90 days.

In addition, the concept of a reportable arrangement will be limited to arrangements that are implementable.

DAC7 and DAC8: expanding the transparency ecosystem

DAC7 and DAC8 further expand tax authorities' visibility over digital economic activity and crypto-assets. Combined with advances in data analytics, these reporting frameworks significantly reduce the possibility of discrepancies remaining undetected.

The proposal adjusts DAC7 reporting for taxpayers that sell goods through digital platforms. The current activity threshold would be removed while the minimum sales reporting threshold would be increased from €2,000 to €3,000.

Data quality becomes a priority

The proposal introduces a centralized Tax Identification Number (“TIN”) verification tool capable of digitally validating taxpayer identification numbers before information is reported. This initiative is intended to improve the accuracy of information exchanges and reduce subsequent corrections.

One of the key simplification measures proposed under the DAC Recast is the expansion of the concept of available information. Under the current framework, tax authorities are generally expected to exchange information that is available in their own tax records and databases. The proposal broadens this definition to include information held across all national government registers and databases, not only those maintained by tax administrations. This change is intended to enhance the completeness and quality of information exchanged between Member States

Enhanced transparency over beneficial ownership

The proposal introduces new exchanges of beneficial ownership information in relation to real estate and aligns the DAC framework with developments under the revised anti-money laundering regime. Tax authorities are expected to benefit from expanded access to interconnected ownership information across the EU.

What does this mean for Romanian taxpayers?

For Romanian businesses, the DAC Recast means simplification of certain reporting obligations but also a signal that tax authorities expect information reported under different frameworks to be consistent, reconcilable and supported by robust governance processes.

In particular, taxpayers should consider:

• reviewing DAC6 assessment and reporting frameworks;
• reconciling CbCR disclosures with transfer pricing documentation;
• assessing status of Pillar Two compliance and reporting;
• review filling obligations for revenues obtained by means of rental or sales activities on digital platforms and crypto assets transactions.

_{[1] Performance Report for 2025 issued by the National Agency for Fiscal Administration.}

_{[2] Category A hallmarks represent generic indicators of potentially aggressive tax planning and cover confidentiality clauses, success-based fee arrangements and standardised tax products. Under the current DAC6 framework, these hallmarks are reportable only where the Main Benefit Test is satisfied.}