CFE Opinion Statement on the EU Consultation on the DAC Recast
PAC 1/2026
CFE strongly supports the consolidation of DAC1–DAC9 into a single, coherent legislative instrument. The recast represents an important opportunity to address structural shortcomings identified through implementation experience and expert input, while maintaining the core objectives of transparency and effective administrative cooperation.
It recommends aligning and effectively merging DAC4 and DAC9 reporting frameworks to eliminate duplication and prevent double reporting, including through the introduction of a centralised group reporting model and a notification-of-changes-only approach.
With respect to DAC6, CFE recommends extending the reporting deadline from 30 to 90 days, reassessing and periodically reviewing hallmarks to ensure clarity and proportionality, and introducing a taxpayer-only reporting obligation to eliminate duplicative intermediary reporting and better align with legal professional privilege frameworks across Member States.
CFE also calls for stronger proportionality safeguards, codification of taxpayer rights recognised in CJEU case law, and the systematic publication of consolidated DAC texts following amendments in order to enhance accessibility and legal certainty.
