What DAC7 regulates and who bears the obligation
DAC7 is the common name for Council Directive (EU) 2021/514 of 22 March 2021 amending Directive 2011/16/EU on administrative cooperation in the field of taxation. Bulgaria transposed it by amendments to the Tax and Social Insurance Procedure Code (TIPC) promulgated in State Gazette issue 100 of 2022 and in force from 1 January 2023. The rules sit in Section VIII of Chapter Sixteen, "Special proceedings".
The obligation rests on the platform operator. An operator is the entity that concludes contracts with sellers for making available the platform or part of it (Art. 143я6(1) TIPC). The seller files nothing under DAC7. The seller's duty is a different one: to declare their income under the ordinary rules and to give the platform the data it is required to collect.
Worth being clear about: DAC7 is an information measure. It introduces no new tax and changes no rate. What changes is visibility — income that previously reached the National Revenue Agency (NRA) only through your own return now arrives by a second, independent channel as well.
A note on the citations in this article. Bulgarian statutes number inserted provisions with a Cyrillic letter and an index, so the DAC7 rules run from Art. 143я5 to Art. 143я13 TIPC. Those are the references you will need to find the text on lex.bg or to quote in correspondence with the revenue authority.
Which platforms report under DAC7 in Bulgaria
Operators with their seat, place of management or permanent establishment in an EU Member State report to the competent authority of that state, and the NRA receives the data on Bulgarian sellers through automatic exchange. Operators established outside the EU that facilitate relevant activity of sellers from Member States register with the authority of a Member State of their choosing when they begin the activity (Art. 143я7(1) TIPC). Where they choose Bulgaria, registration is with the Executive Director of the NRA.
The Executive Director of the NRA exchanges the information received with the competent authorities of the other Member States and of the partner jurisdictions within two months of the end of the calendar year to which the information relates (Art. 143я5(5) TIPC) — that is, by the end of February.
The practical consequence for a seller is that it does not matter where the platform is incorporated. A marketplace based in Ireland, the Netherlands or outside the EU altogether ends up sending your figures to the same place.
Which activities and which sellers are within scope
The law works with two concepts. Relevant activity is exhaustively listed in Art. 143я9(5) TIPC and covers four categories of activity, where carried out for consideration:
| Relevant activity (Art. 143я9(5) TIPC) | Typical platforms | Exemption threshold |
|---|---|---|
| Rental of immovable property — residential and commercial property, parking spaces and other | Booking.com, Airbnb, Vrbo | None |
| Personal service | Upwork, Fiverr, food-delivery and service platforms | None |
| Sale of goods | Amazon, eBay, Etsy, Vinted, OLX | Fewer than 30 transactions and up to EUR 2,000 |
| Rental of any means of transport | Turo, GetAround and similar | None |
Relevant activity does not include activity carried out by a seller acting as an employee of the platform operator or of an entity related to it (Art. 143я9(6) TIPC).
Active seller
A seller is any individual or entity registered as a user of the platform at any point during the reportable year and carrying out relevant activity (Art. 143я9(1) TIPC). A seller is active where during that year they carry out relevant activity, or consideration is paid or credited to them in connection with such activity (para. 3). Information is provided on an active seller who is resident in Bulgaria, in another Member State or in a partner jurisdiction, and on anyone who has rented out property situated in such a state (para. 2).
Excluded sellers
Four categories fall outside the report altogether (Art. 143я9(4) TIPC): governmental entities; entities whose shares are regularly traded on a securities trading venue, and their related entities; entities with more than 2,000 relevant rental activities in respect of a single listed property for the year; and sellers of goods below the threshold. An ordinary EOOD selling online falls into none of them.
The EUR 2,000 threshold applies only to the sale of goods
This is the provision most often cited inaccurately. Art. 143я9(4)(4) TIPC treats as an excluded seller one for whom the operator facilitated fewer than 30 relevant activities by way of the sale of goods and whose total consideration did not exceed EUR 2,000 during the reportable year. The two conditions operate together: only a seller who satisfies both is exempt. One of them failing is enough to bring the seller into the report.
Note the wording. The threshold is tied to the words "by way of the sale of goods". For rental of immovable property, for personal services and for rental of means of transport there is no de minimis threshold at all. A single night booked through Booking, or a single order through a services platform, is enough for you to appear in the report to the NRA.
The threshold is assessed per platform. A seller with EUR 1,800 of turnover on Amazon and EUR 800 on Etsy is below the threshold on each of them, provided the number of transactions is also under 30 — and on that basis neither platform is obliged to include that seller in its report. The combined EUR 2,600 is not aggregated across platforms.
If you let out property, the position for hosts is set out in more detail in our article on DAC7 obligations for Booking and Airbnb hosts. For individuals selling goods, we deal separately with when the income is taxable in online sales by individuals, and for creator income in taxation of influencers.
From our practice: the DAC7 threshold is a reporting threshold, not a taxing threshold. Turnover below EUR 2,000 does not make income non-taxable, and turnover above the threshold does not make it automatically taxable — the characterisation is made under the Personal Income Taxes Act (PITA) or the Corporate Income Tax Act (CITA) regardless of whether a platform has reported you.
What data about you reaches the NRA
The content of the report is set out in Art. 143я8(1) TIPC. For a seller carrying out relevant activity other than the rental of immovable property, the operator provides:
- name or business name, principal address, and date of birth for individuals;
- tax identification number and the state that issued it, or, where there is none, the place of birth;
- the commercial registration number where the seller is an entity, and the VAT identification number where there is one;
- the identifier of the financial account into which the consideration is paid, and the name of the account holder where it differs from the seller's name;
- each Member State or partner jurisdiction in which the seller is resident, and the states in which they have a permanent establishment;
- the total consideration for each quarter and the number of relevant activities, together with the fees, commissions and taxes withheld for each quarter.
Where immovable property is let, the address of each listed property and its cadastral identifier are added, together with the consideration and number of activities for each individual property and, where known, the number of days the property was let and its type (Art. 143я8(1)(3) TIPC).
The information is filed electronically, in the manner and format approved by order of the Executive Director of the NRA (para. 2). The operator also notifies the NRA where it has no information to provide (para. 3) — the nil report is an obligation too.
Reconciling those figures against your accounts is rarely mechanical. If you have mixed income streams, several platforms or a non-resident element, ask us to review the position before you file.
Deadlines: 31 January and what follows
The operator provides the information to the NRA by 31 January of the year following the reportable year (Art. 143я11(1) and (4) TIPC). The regime has applied since 2023, so the first reporting was due by 31 January 2024 for 2023 data. For calendar year 2025 the deadline fell on 31 January 2026, and 2026 data is due by 31 January 2027.
| Action | Deadline | Provision |
|---|---|---|
| Platform files the report with the NRA | 31 January of the following year | Art. 143я11(1) and (4) TIPC |
| Platform also provides the data to the seller | 31 January of the following year | Art. 143я11(6) TIPC |
| NRA exchanges the information with other Member States | within two months of the end of the reportable year | Art. 143я5(5) TIPC |
| Annual tax return — individuals | 10 January – 30 April | Art. 53 PITA |
| Annual tax return — EOOD and OOD | 1 March – 30 June | Art. 92 CITA |
The duty under para. 6 is often overlooked and is genuinely useful: the platform must give you the same data it sends to the NRA. Ask for it and reconcile it against your accounts before you file. That is the cheapest moment at which to find a discrepancy.
Currency from 2026
Consideration is reported in the currency in which it was paid or credited. Where it was paid in another manner, the information is provided in the euro equivalent, converted in a way determined consistently by the operator (Art. 143я11(7) TIPC, as amended in State Gazette issue 70 of 2024, in force from 1 January 2026).
Penalties: what Art. 278д TIPC provides
The sanctions are imposed on the platform operator. The amounts are fixed in Art. 278д TIPC and are stated in the Code in Bulgarian leva; the euro equivalent is at the official rate of BGN 1.95583 to EUR 1.
| Breach | Pecuniary sanction | Provision |
|---|---|---|
| Report not filed on time | BGN 5,000 – 10,000 (EUR 2,556 – 5,113) | Art. 278д(1) |
| Incomplete or incorrect information provided | BGN 250 (EUR 127.82) for each seller | Art. 278д(2) |
| Due diligence not carried out, or carried out in breach | BGN 100 (EUR 51.13) for each seller | Art. 278д(3) |
| Operating without registration (non-EU operator) | BGN 5,000 – 10,000 (EUR 2,556 – 5,113) | Art. 278д(4) |
| Seller not notified of the amounts reported | BGN 500 (EUR 255.65) for each person | Art. 278д(7) |
| Documentation not retained | BGN 1,000 – 5,000 (EUR 511 – 2,556) | Art. 278д(8) |
On a repeated breach the sanction is doubled (Art. 278д(9) TIPC). Note the construction of paras 2 and 3: they are charged per seller, which for a platform with several thousand active sellers makes the exposure incomparable with the fixed amounts under para. 1.
What the seller risks
The seller bears no sanction under Art. 278д — they have no reporting obligation. Their exposure is of a different kind. A discrepancy between the amounts reported by the platform and the income declared is a concrete ground for assigning an audit under Art. 112 TIPC, and interest under Art. 175 TIPC accrues on any liability established.
If you have received an enquiry from the NRA following DAC7 reporting, take advice before you answer. The first response frames the whole of the proceedings that follow.
If you do not give the platform your data
The due diligence procedure under Art. 143я10 TIPC requires the platform to collect and verify your data. Refusal has an expressly regulated consequence: after the expiry of a 60-day period from the initial request and at least two written reminders, the operator terminates the seller's registration and does not allow them to re-register — or withholds payment of the consideration until it receives the information requested (Art. 143я13(1) TIPC).
In practice this means blocked payments on an account that continues to generate obligations towards customers. The operator retains the records and documents for a period of not less than 5 and not more than 10 years after the end of the reportable year (para. 2) — the window during which the data remains available for a later check.
Preparing as an EOOD that sells through a platform
An EOOD selling through a marketplace is a seller for DAC7 purposes. The platform will ask for the UIC (the unified identification code of the company), the registered address of management as recorded in the Commercial Register, the VAT identification number where there is one, and the bank account identifier. The data in the profile must match what is entered in the Commercial Register — a mismatch blocks verification, and with it the payments.
- Reconcile by quarter. The NRA receives your turnover broken down quarterly. Your bookkeeping needs to produce the same breakdown.
- Document the differences. Platform commissions, the VAT component, cancelled orders and exchange differences are all legitimate reasons for a discrepancy — but each is proved by a document.
- Check your VAT status. Compulsory registration arises where taxable turnover exceeds EUR 51,130 for the calendar year (Art. 96(1) VAT Act, as amended in State Gazette issue 115 of 2025, in force from 1 January 2026). See VAT registration in Bulgaria.
- Request your data from the platform under Art. 143я11(6) TIPC and check it before filing the return under Art. 92 CITA.
The tax regime itself is unchanged
DAC7 does not touch the rates. For an EOOD they remain 10% corporate tax on taxable profit (Art. 20 CITA) and 5% tax on dividends when profit is distributed to the owner as an individual (Art. 38(1) in conjunction with Art. 46(3) PITA). The combined burden on distributed profit is 15%. The detail is in our article on corporate tax in Bulgaria, and if you are still structuring the activity, in registering an EOOD.
Which is to say: what DAC7 in Bulgaria changes is not what you owe but what the revenue authority can see. The sensible response is not to restructure, but to make sure the figures you declare and the figures the platform reports tell the same story.
A review of your DAC7 position before the NRA makes one
We check the fit between what the platforms have reported and what you have declared: reconciling quarterly statements against the accounting records, reviewing the registration data against the Commercial Register, assessing VAT status, and taking a position where a discrepancy has already been identified. For platform operators — a review of the due diligence procedures and of the reporting process against Section VIII TIPC. Describe the situation briefly and we will tell you what we think the priority is.
Frequently asked questions
If I am below EUR 2,000, will the platform report me?
It depends what you sell. The threshold exempts only sellers of goods, and then only where two conditions are met at the same time: fewer than 30 transactions and up to EUR 2,000 for the year (Art. 143я9(4)(4) TIPC). For rental of immovable property, personal services and rental of means of transport no threshold exists and reporting starts with the first transaction. Regardless of the threshold, the platform must still collect and verify your data under Art. 143я10 TIPC.
What does the NRA do with the data and how is it matched against my return?
The NRA receives an electronic structured report with the quarterly amounts and the number of transactions for each reportable seller. The data is compared against the annual returns filed — under Art. 53 PITA for individuals (10 January – 30 April) and Art. 92 CITA for companies (1 March – 30 June). Where a discrepancy is identified, an audit may be assigned under Art. 112 TIPC, and interest under Art. 175 TIPC accrues on the liability established.
Can I be an EOOD and still be caught by DAC7 as a seller?
Yes. DAC7 does not distinguish between individuals and legal entities — a seller is any person or entity registered as a user of the platform and carrying out relevant activity (Art. 143я9(1) TIPC). Only governmental entities, publicly traded companies and their related entities, entities with more than 2,000 rentals of a single listed property per year, and sellers of goods below the threshold are excluded. An ordinary trading company falls into none of these categories.
What are the DAC7 penalties and who pays them?
The sanctions under Art. 278д TIPC are imposed on the platform operator, not on the seller. A report not filed on time carries a pecuniary sanction of BGN 5,000 to 10,000; incomplete or incorrect information, BGN 250 for each seller affected; and due diligence not carried out, BGN 100 for each seller. On a repeated breach the amount is doubled (para. 9). The seller bears no sanction under this head, but remains liable under the general rules for undeclared income.
Sources
- Tax and Social Insurance Procedure Code — Section VIII of Chapter Sixteen, Art. 143я5 – 143я13 (new — State Gazette issue 100 of 2022, in force from 1 January 2023; amended — State Gazette issue 70 of 2024) and Art. 278д
- Council Directive (EU) 2021/514 of 22 March 2021 — EUR-Lex
- Corporate Income Tax Act — Art. 20 and Art. 92
- Personal Income Taxes Act — Art. 38(1), Art. 46(3) and Art. 53
- National Revenue Agency
- Administrative cooperation in the field of direct taxation — European Commission
- Commercial Register and Register of Non-Profit Legal Entities — Registry Agency
This material is for information only and reflects the law as at 28 July 2026. It is not legal advice on any particular matter.