Classifieds Marketplaces Europe

CME submission to public consultation on the DAC7 recast ​ 9 February 2026 Classifieds Marketplaces Europe (CME), a coalition of European second-hand online marketplaces, including Adevinta, OLX, Vend, Vinted, Wallapop, and CustoJusto, welcomes the opportunity to contribute to the European Commission’s reflections on the functioning of the Directive on Administrative Cooperation (DAC).​ Introduction While Classifieds Marketplaces Europe supports the objectives of DAC7 and the fight against tax evasion and avoidance, we believe that a revision of this framework could significantly improve its effectiveness and proportionality. The implementation thus far has shown that the current framework produces significant disproportionate and unintended negative effects on second-hand marketplaces, while delivering limited incremental value for tax compliance.

…unintended negative effects on second-hand marketplaces, while delivering limited incremental value for tax compliance. We strongly believe that targeted policy adjustments, combined with practical implementation improvements, would significantly enhance effectiveness, reduce unnecessary administrative burdens, and ensure better alignment with the EU’s broader objectives on simplification, competitiveness and the circular economy. In this context, CME invites the Commission to consider the following:​ ●​ Revising the existing thresholds for triggering reporting obligations to better reflect the reality of second-hand marketplaces;​ ●​ Extending the reporting deadline. Our experience with DAC7 ​ Disproportionate impact on private individuals selling second-hand goods CME members’ marketplaces have a unique business model.

…impact on private individuals selling second-hand goods CME members’ marketplaces have a unique business model. The vast majority of their users are private individuals who are simultaneously buyers and sellers, and who occasionally sell goods they, or their family members, no longer use. These items are typically sold at a lower price than originally paid and without any intention to make a profit. Such occasional, non-commercial transactions rarely generate taxable income. However, the current thresholds (30 transactions or 2.000 euros per year) are removed from the reality of a functioning circular economy and can be reached very easily. Many users of Ref. Ares(2026)1785589 - 17/02/2026 CME members’ platforms exceed the transaction threshold simply through everyday life events, such as moving house, studying abroad, or passing on children’s items as families grow.

…through everyday life events, such as moving house, studying abroad, or passing on children’s items as families grow. As a result, DAC7 reporting obligations are triggered for large numbers of users who are highly unlikely to be taxable. For this reason, platforms are required to collect and report sensitive personal data, including Tax Identification Numbers (TINs), generating large volumes of low-risk, low-value data. This creates high administrative costs for platforms and considerable “noise” for tax authorities. Confusion, fear and a chilling effect on second-hand trade CME members have observed widespread confusion and anxiety among users following the implementation of DAC7.

…trade CME members have observed widespread confusion and anxiety among users following the implementation of DAC7. Public discussions and media reporting have, at times, lacked sufficient clarity, contributing to the perception among many private sellers that providing a TIN will automatically result in taxation or new tax filing obligations. Despite extensive efforts by CME members to explain DAC7 through help centres, guides and FAQs, confusion remains widespread, and user reluctance persists. User surveys confirm a growing hesitation to list second-hand items, directly affecting trade between private individuals. This reduces the availability of second-hand goods and may push consumers towards buying new products instead, undermining circular consumption habits and contradicting EU objectives to build a more sustainable and circular Single Market.

…circular consumption habits and contradicting EU objectives to build a more sustainable and circular Single Market. Behavioural distortions and consumer harm DAC7 also influences user behaviour in ways that undermine other policy objectives. More concretely, in order to avoid triggering reporting thresholds, some users spread sales across multiple platforms or move to platforms outside the scope of reporting rules. This results in fragmented transaction data, reduced transparency and ultimately weakened tax compliance. In parallel, DAC7 has also become a hook for consumer scams. For example, Wallapop has identified that around 20% of users who mention DAC7 to other users have been identified as scammers, often using the Directive as a pretext to move transactions off-platform and expose consumers to fraud.

…as scammers, often using the Directive as a pretext to move transactions off-platform and expose consumers to fraud. Our proposed way forward 1.​ Revise the existing thresholds​ To address the challenges described above, CME urges the Commission to revise the existing thresholds triggering DAC7 reporting obligations. The preferred solution would be to remove reporting obligations for the sale of goods, including those second-hand. This would align DAC7 with approaches adopted in other OECD jurisdictions, including Norway, and ensure that reporting focuses on areas with genuine tax risk. If reporting obligations for goods are maintained, the existing thresholds should be at least combined (from “OR” to “AND”) and significantly raised to better reflect the reality of a functioning circular economy and target sellers trading for profit.

…raised to better reflect the reality of a functioning circular economy and target sellers trading for profit. The transaction threshold alone has proven irrelevant to the objective of combating tax fraud. As a standalone criterion, it is detached from profit-making behaviour and imposes unnecessary burdens on users, platforms and authorities alike. 2.​ Extend the reporting deadline​ Penalties for non-compliant users cannot legally be enforced until two reminders have been issued and a minimum of 60 days has elapsed. For this reason, the current reporting deadline of 31 January limits effective follow-up and adjustments, including for cancelled transactions, returns, claims, or product recalls.

…limits effective follow-up and adjustments, including for cancelled transactions, returns, claims, or product recalls. In addition, platforms are left with a very short timeframe to comply when sellers trigger thresholds close to year-end, increasing the risk of discrepancies between reported amounts and actual seller turnover. CME therefore proposes extending the reporting deadline in order to improve the accuracy and reliability of reporting, reduce administrative pressure on businesses, and preserve the integrity and effectiveness of DAC7. Conclusion ​ CME welcomes the fact that the Commission is reflecting on the practical implementation and impact of DAC7. We strongly encourage the Commission to pursue the review of DAC7, taking into account the feedback above.

…of DAC7. We strongly encourage the Commission to pursue the review of DAC7, taking into account the feedback above. Experience to date shows that there is substantial room for improvement to ensure the framework is proportionate, effective and aligned with EU priorities on simplification, competitiveness and the circular economy. CME and its members stand ready to support this work by sharing further data, operational experience and user insights, to help ensure that DAC7 achieves its objectives without unintentionally hampering the EU’s transition to a more circular economy. *** About CME Classifieds Marketplaces Europe is a coalition of industry-leading EU-based tech companies, including - Adevinta, OLX, Vend, Vinted, Wallapop, and CustoJusto - operating online classifieds platforms in 21 European countries.

OLX, Vend, Vinted, Wallapop, and CustoJusto - operating online classifieds platforms in 21 European countries. Our aim is to empower citizens to strengthen the circular economy and local communities. By combining our resources, we are raising awareness about the specificities of the online classifieds sector and its positive contribution to key objectives of the EU digital and green agenda. Contact details ​ CME Secretariat: [email protected] CME Chair: Angelica Viggiano [email protected]

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