Dublin: The DAC recast, which would merge the nine existing directives on administrative cooperation in tax into one text, has become the Irish Presidency’s main tax target for the final weeks of 2026. The Presidency aims to conclude negotiations on the DAC recast by December, according to an EY summary of the Commission proposal.
The Commission released the proposal on 24 June 2026 alongside a separate tax omnibus, as part of its simplification drive. The DAC recast replaces Council Directive 2011/16/EU and consolidates DAC1 to DAC9, so tax authorities, platforms and multinationals would work from a single legal framework. The Commission explains the wider package in its press release on tax simplification.
The biggest practical change concerns mandatory disclosure of cross-border arrangements, known as DAC6. The Commission would extend the reporting deadline from 30 to 90 days and start the clock when the first implementation step takes place. It would drop the generic Category A hallmarks and remove the definitions of marketable and bespoke arrangements, which have caused disputes over what counts as reportable.
Pillar Two groups gain relief. Arrangements in which every participant belongs to a group covered by the global minimum tax would fall outside DAC6, unless the ultimate parent sits in a qualified side-by-side jurisdiction. KPMG reads the exemption more narrowly and adds a condition tied to an effective tax rate of 15 percent, while EY does not, so companies should check the legal text before they rely on it.
Digital platforms also feel the change. The DAC recast removes the 30-sales activity threshold under DAC7 and raises the monetary threshold for goods sales from €2,000 to €3,000. The proposal also changes the definition of excluded platform operators for firms that facilitated less than €50,000 in the previous year, a detail smaller marketplaces should check in the text.
For large groups, the Commission proposes one group-level notification for companies that must file both country-by-country reports and Pillar Two information returns. It also adds a digital tool to verify tax identification numbers and updates tax authorities’ access to anti-money-laundering data, including beneficial ownership and bank account registers.
Timing matters. Most disclosure changes and the DAC7 threshold would apply from 1 January 2028, and the remaining provisions, including the repeal of the old directives, from 1 January 2030. The Council must agree unanimously, while the European Parliament only gives a non-binding opinion, so a single capital can still block progress.
Unanimity makes December an ambitious target, and the tax omnibus will probably run into 2027. If finance ministers close the DAC recast on schedule, Europe’s tax transparency rules will become shorter and easier to apply. If they miss it, businesses will keep navigating nine overlapping directives for another year while the DAC recast waits for a deal.
