European Savings and Retail Banking Group

Información Confidencial ESBG response to the Commission’s public con- sultation on the possible recast of the DAC ESBG (European Savings and Retail Banking Group) Rue Marie-Thérèse, 11 - B-1000 Brussels February 2026 Ref. Ares(2026)1437185 - 09/02/2026 0035/26 MKA 2 Información Confidencial Dear Sir/Madam, Thank you for the opportunity to comment on the DAC consultation. The European Savings and Retail Banking Group (ESBG) would like to provide you with the comments below, which we hope will be considered by the Commission. QUESTIONNAIRE DAC general The DAC prescribes the standardised IT reporting format (schema) for exchange of information between Member States’ tax authorities. This is applied in a harmo- nised manner across the EU.

…exchange of information between Member States’ tax authorities. This is applied in a harmo- nised manner across the EU. However, there is no harmonisation of the domestic reporting format that the relevant tax authorities of the Member States require for reporting by the business of DAC information. Some Member States use the schema prescribed in DAC with little or no modifications while some Member States develop their own national reporting schemas, which can create an addi- tional burden for business, especially those that report in several Member States. Would you be in favour of making the schema used for the exchange of infor- mation between Member States’ tax authorities also mandatory for the reporting of information by reporting entities to tax authorities, in all Member States? a) No, we would not be in favour of this.

…information by reporting entities to tax authorities, in all Member States? a) No, we would not be in favour of this. There are countries (such as the Netherlands) where the CRS reporting is part of the national reporting. Hav- ing a single mandatory schema across the EU would make this impossible. In how many Member States did you report last year? 7 Under which DAC(s) did you report last year? a) DAC2 b) DAC4 c) DAC6 Cost of reporting per report (or an average if you report under different DAC) 0035/26 MKA 3 Información Confidencial The costs are neg- ligible The costs are limited The costs are high Very high costs I don’t know/not appli- cable One-off costs (IT and training) X Recurrent costs X Please provide a quantification of cost estimations for the current annual notification regime. Quantification can be made in monetary terms or in FTE.

…of cost estimations for the current annual notification regime. Quantification can be made in monetary terms or in FTE. For advisors, please indicate the average. If precise estimations are no available, please provide a range. Quantification One-off cost c.€1.000.000 Recurrent annual cost c.€750.000 DAC4 / DAC9 Currently DAC4 requires an MNE group to notify every year the reporting entity for the MNE group and the names of the entities which form part of the Group. Would you be in favour of removing this obligation and instead requiring only the notification of changes in the group? a) Yes In how many Member States do you notify?

…and instead requiring only the notification of changes in the group? a) Yes In how many Member States do you notify? 7 Cost of reporting per notification The costs are negligible The costs are limited The costs are high Very high costs I don’t know/not applicable One-off costs (IT and training) X Recurrent costs X 0035/26 MKA 4 Información Confidencial Please provide a quantification of cost estimations for the current annual notification regime. Quantification can be made in monetary terms or in FTE. For advisors, please indicate the average. If precise estimations are no available, please provide a range. Quantification One-off cost c.€50.000 Recurrent annual cost c.€100.000 Please provide a quantification of cost savings estimations where only the notification of changes in the group is introduced. Quantification can be made in monetary terms or in FTE.

…only the notification of changes in the group is introduced. Quantification can be made in monetary terms or in FTE. For advisors, please indicate the average. If precise estimations are no available, please provide a range. Quantification One-off cost savings Recurrent annual cost savings c.€25.000 The Pillar 2 Directive (P2D) provides Member States with discretion to design the notification process for the entities in scope, which has led to divergent approaches across Member States. Furthermore, the notification required by P2D is very similar, in some respects, to the notification required by DAC4. Would you be in favour of combining the notifications for the purposes of DAC4 and P2D? a) Yes DAC4 In how many Member States do you notify?

…of combining the notifications for the purposes of DAC4 and P2D? a) Yes DAC4 In how many Member States do you notify? 7 Cost of reporting per notification The costs are negligible The costs are limited The costs are high Very high costs I don’t know/not applicable One-off costs (IT and training) X Recurrent costs X 0035/26 MKA 5 Información Confidencial Please provide a quantification of cost estimations for the DAC4 notification under the current situation requiring separate notifications for the purposes of DAC4 and P2D. Quantification can be made in monetary terms or in FTE. If precise estimations are no available, please provide a range. Quantification One-off cost Recurrent annual cost Pillar 2 Directive In how many Member States do you notify?

…a range. Quantification One-off cost Recurrent annual cost Pillar 2 Directive In how many Member States do you notify? 7 Cost of reporting per notification The costs are negligible The costs are limited The costs are high Very high costs I don’t know/not applicable One-off costs (IT and training) X Recurrent costs X Please provide a quantification of cost estimations for the P2D notification under the current situation requiring separate notifications for the purposes of DAC4 and P2D. Quantification can be made in monetary terms or in FTE. For advisors, please indicate the average. If precise estimations are no available, please provide a range. Quantification One-off cost Recurrent annual cost Please provide a quantification of cost estimations if notification for the purposes of DAC4 and P2D are combined. Quantification can be made in monetary terms or in FTE.

…if notification for the purposes of DAC4 and P2D are combined. Quantification can be made in monetary terms or in FTE. For advisors, please indicate the average. If precise estimations are no available, please provide a range. Quantification One-off cost 0035/26 MKA 6 Información Confidencial Recurrent annual cost Currently there are two different reporting schemas under DAC4 and DAC9 with numerous overlapping fields. Would you be in favour of merging the two reporting schemas to prevent possible overlaps and double reporting? a) Yes Please provide a quantification of cost saving estimations where the two reporting schemas are merged. Quantification can be made in monetary terms or in FTE.

…saving estimations where the two reporting schemas are merged. Quantification can be made in monetary terms or in FTE. For advisors, please indicate the average (*) (*) if precise estimations are no available, please provide a range Quantification One-off cost savings Recurrent annual cost savings c.€25.000 DAC6 DAC6 foresees that any potentially harmful cross-border tax arrangement needs to be reported within 30 days after the arrangement has been made available. Would you support a longer deadline to report an arrangement? In that respect, reasonable extended deadlines, also based on other existing deadlines in DAC, could be 60 days or 90 days. a) Yes - 60 days b) Yes - 90 days c) No d) No opinion Please clarify: ........ According to the findings from the DAC evaluation, reporting under DAC6 generates significant costs for the intermediaries and taxpayers.

…from the DAC evaluation, reporting under DAC6 generates significant costs for the intermediaries and taxpayers. Can you please provide estimations of the costs incurred. For taxpayer Cost of reporting per report 0035/26 MKA 7 Información Confidencial The costs are negligible The costs are limited The costs are high Very high costs I don’t know/not applicable One-off costs X Recurrent costs X Please provide a quantification of cost estimations. Quantification can be made in monetary terms or in FTE. If quantifications are not available, please provide a range. Quantification One-off cost N/A Recurrent cost N/A For intermediaries Cost of reporting per report The costs are negligible The costs are limited The costs are high Very high costs I don’t know/not applicable One-off costs X Recurrent costs X Please provide a quantification of cost estimations.

…provide a quantification of cost estimations. Quantification can be made in monetary terms or in FTE. If quantifications are not available, please provide a range. Quantification One-off cost c.€25.000 Recurrent cost c.€150.000 As indicated in the DAC evaluation, the Main benefit test (MBT) and the connected hallmarks A1, A2 and A3 have been highlighted as difficult to apply and as creating significant administrative burden due to its inherent complexity and divergent interpretation of the concept across Member States. Do you agree with the outcome of the DAC evaluation on this issue? a) No opinion 0035/26 MKA 8 Información Confidencial Please explain: ......

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