What Content Creators Need to Know About DAC7 Reporting & Platform Rules in 2025

Introduction

The landscape of taxation for the European Union’s (EU) content creator community is undergoing a significant shift with the implementation of DAC7. This directive now requires every digital platform to report seller earnings directly to tax authorities, making income from all sources highly visible and creating new compliance challenges for 2025.

For any content creator, this new era of transparency means that understanding what constitutes taxable income and the potential penalties for non-compliance is more critical than ever. This guide provides essential information on the DAC7 reporting rules, offering clarity on these obligations and highlighting why creators with international income may need to consult an international estate planning lawyer for guidance on managing overseas assets effectively.

Understanding DAC7 & How It Affects Content Creators

Defining the Reportable Seller

Under the DAC7 reporting rules, a “reportable seller” is defined as an individual or company residing in the EU that uses a digital platform to engage in specific commercial activities. Digital platforms are required to report information on any content creator who meets this definition.

Non-EU residents who earn income from renting out immovable property located within the EU are also considered reportable sellers.

For content creators selling goods, the reporting obligation is triggered when certain thresholds are met within a calendar year. You are considered a reportable seller if you:

• Complete 30 or more sales of goods, or
• Earn more than €2,000 in total consideration from these sales.

It is important to note that for personal services or property rentals, there is no minimum threshold. This means that even a single transaction can make you a reportable seller, and the digital platform operator must report your earnings.

The Scope of Relevant Activities for Creators

The DAC7 directive specifies certain commercial activities, known as “Relevant Activities,” that fall within its scope. For content creators, the most common reportable activities involve the sale of goods and the provision of personal services. These activities are central to the new compliance requirements for any EU-based seller.

The primary activities covered by DAC7 reporting include:

Activity Type	Description & Scope
Sale of Goods	Applies to creators selling merchandise, handmade items, or other tangible products through platforms like Etsy or Amazon.
Personal Services	Covers time- or task-based work performed at a user’s request, such as freelance services, coaching, or customised content.
Rental of Transport	Includes services that allow users to rent any mode of transport.
Rental of Immovable Property	Applies to short-term accommodation rentals through platforms like Airbnb.
Excluded Activities	Platforms used exclusively for payment processing, advertising, or redirecting users, as well as investment-based crowdfunding, are outside the scope of DAC7 reporting.

However, not all platform activities are subject to DAC7 reporting. The rules specifically exclude:

• Platforms used exclusively for payment processing, advertising, or redirecting users to another platform
• Activities such as investment-based crowdfunding, which are outside the scope of these reporting obligations

Determining Which Twitch Streamers & TikTokers Are Affected by DAC7

Distinguishing Personal Services from Standardised Content

Under DAC7, a key factor for a content creator is whether their work qualifies as a “personal service.” This term refers to time or task-based work that is performed at the specific request of a user, meaning it involves some level of customisation.

Many activities common to Twitch streamers and TikTokers may not meet this requirement. Standardised, pre-recorded digital content generally falls outside the scope of DAC7 reporting because it lacks the necessary element of personalisation. For example, the following activities are typically not considered personal services:

• Uploading standard videos or photos to a social media platform for general viewing.
• Offering pre-recorded content with general advice on topics like fitness or finance.
• Conducting a standard livestream, such as a gamer playing a video game on Twitch, where the audience simply watches.

Conversely, when a content creator offers customised services that are influenced or directed by a user for a fee, these activities are likely to be reportable. For instance, imagine a scenario where a follower pays a streamer to perform a specific action or side quest during a live video game. This interaction transforms the activity into a personal service, as it is carried out at the request of a user.

Other examples include:

• Providing one-to-one coaching sessions for a fee.
• Creating personalised video messages for a fee.

Reporting on Mixed Activities & Consideration

A significant challenge arises when a content creator engages in “mixed activities,” earning income from both standardised content and customised personal services. For a digital platform, it can be difficult to distinguish the portion of a creator’s earnings that is tied specifically to reportable personal services, especially if all funds are combined in a single digital wallet.

This ambiguity creates a reporting dilemma for the platform operator. According to guidance from the Organisation for Economic Co-operation and Development (OECD), if a service contains both reportable and non-reportable elements that cannot be easily separated, the entire service may become subject to DAC7 reporting.

The only exception is if the personal service component is considered “purely ancillary” to the main, non-reportable service. However, the term “purely ancillary” is not clearly defined, leaving platforms to make a judgment call.

To avoid potential penalties for non-compliance, a platform might choose to report the creator’s entire income. Consequently, a content creator who earns money from both general streaming and paid, customised user requests could find all their earnings on that platform reported to tax authorities.

A Step-by-Step Guide to Completing the Tax Interview for Influencers

Accessing & Completing the Twitch Tax Interview

To maintain compliance with DAC7 reporting rules, monetising streamers in the EU must complete a new tax interview. Digital platform operators like Twitch are required to collect this information to avoid penalties such as blocked payouts for the content creator.

You can complete the required interview by following these steps on a desktop browser:

• Go to your Creator Dashboard and select Settings, then choose Affiliate/Partner.
• Click on the link labelled New DAC7 Tax Interview to begin the process.
• The interview, which uses Amazon Tax Central, should take less than five minutes, as basic information like your legal name and address may be pre-filled.

Once your information is submitted and accepted, the status will show as Completed.

If there are issues, the status may update to:

• Incomplete
• Pending
• Failed

In these cases, you will need to restart the process with corrected information.

Validating VAT Numbers & Identity Information

During the tax interview, you will be required to provide a Tax Identification Number (TIN) or a Value-Added Tax (VAT) number for verification. This information is essential for the platform to fulfil its reporting obligation.

Platforms verify these numbers using official EU databases, such as the VAT Information Exchange System (VIES), to ensure accuracy.

If you encounter an “invalid code” error when entering your VAT number, it may mean you are not registered in the VIES database. In such cases, you should contact a tax adviser to resolve the issue.

For creators who do not have a VAT number, there is typically an option to select a checkbox indicating this.

It is crucial to enter the correct format for your country’s VAT number. For example:

Country	VAT Number Format / Identifier
Austria	Starts with ‘U’ followed by 9 numbers.
Germany	A 9-digit number known as the Umsatzsteuer-Identifikationsnummer.
France	An 11-character number starting with letters or numbers.
Spain	The Número de Identificación Fiscal (NIF) or Número de Identificación Extranjero (NIE) is collected.

For a content creator with complex, cross-border income streams or assets, understanding the significance of taxation in international estate planning can be challenging. In these situations, consulting with a specialist, such as an international estate planning lawyer, is advisable to manage global wealth and ensure long-term compliance.

VAT & Income Tax Reporting Obligations for EU Creators

Data Shared with Tax Authorities

Under the DAC7 reporting rules, digital platform operators must collect, verify, and share specific information about their sellers with EU tax authorities. This process ensures that the income a content creator earns is visible to the relevant tax bodies, with reporting completed annually by January 31st of the year following the calendar year in which the income was earned.

The data that platforms must report includes a combination of personal and financial details, such as:

Data Category	Details Reported to Tax Authorities
Seller Identification	For individuals: full name, primary address, date of birth, and TIN. For businesses: legal name, business registration number, and TIN.
Financial Account Details	Information about the bank account to which payments are credited.
Total Consideration	The gross amount paid or credited to the seller each quarter, before any fees or commissions are deducted.
Transaction Data	The total number of relevant activities performed during the reporting period.
Fees and Taxes	Any fees, commissions, or taxes that the platform has withheld or charged.
Property Information	For creators renting out immovable property, the full address of the property must also be reported.

Understanding Taxable Income & Barter Transactions

A common misconception for any content creator is that only cash payments are considered taxable income. However, tax authorities view any form of payment received in exchange for work as potentially taxable, including non-cash items and services, often referred to as “barter transactions.”

If a brand provides you with products or services with the expectation of a promotion, the fair market value of those items is considered taxable income. For example:

• If a fashion brand sends you a €1,500 shoes in exchange for an Instagram post, that value must be declared as income.
• The same principle applies to all-expenses-paid press trips; if a hotel provides flights and accommodation in return for a vlog, the value of that trip is taxable.

The key factor is whether there was an obligation to provide a promotional service.

VAT Registration Thresholds & Obligations

Content creators must monitor their total turnover to determine if they need to register for VAT. Each EU country has its own VAT registration threshold, and once a creator’s income exceeds this limit within a rolling 12-month period, they are legally required to register. This turnover includes all taxable income streams, such as:

• Ad revenue
• Brand collaborations
• Subscriptions

For a content creator selling digital products like courses or e-books to customers in different EU countries, the VAT One-Stop-Shop (OSS) scheme may be necessary. This system allows you to register for VAT in a single EU member state and file one return for all your cross-border digital sales, simplifying compliance.

Given the complexities of varying international VAT rules and managing diverse income streams, it’s crucial to understand why asset protection is important when structuring your global assets and ensuring long-term tax compliance.

Potential Penalties for Non-Compliance by Platform Sellers

Financial Consequences & Blocked Payouts

A primary penalty for failing to comply with DAC7 reporting rules is the immediate financial impact of blocked payouts. Digital platform operators are legally required to withhold payments from any content creator who does not provide the necessary tax information within the specified timeframe.

For example, if a seller on a platform like Twitch fails to complete the required tax interview:

• They may continue to earn revenue from their activities.
• However, the platform will not issue any payouts until the DAC7 compliance steps are completed.

These funds are held until the creator provides the necessary tax information, at which point the withheld earnings are released in the next payment cycle. This measure ensures that the reporting obligation is taken seriously, as it directly affects a creator’s cash flow.

Account Suspension & Offboarding Risks

Beyond withholding funds, non-compliance with DAC7 can lead to more severe actions, including:

• Account suspension
• Complete offboarding from a platform’s monetisation programs

If a content creator is offboarded, they lose the ability to earn any revenue from sources such as subscriptions, advertisements, or fan donations. This effectively demonetises the creator’s channel, preventing them from generating income on that digital platform.

While they may still be able to broadcast or post content, their primary revenue streams will be cut off. To begin earning again, the creator would need to re-onboard and complete all required tax interviews. This process could result in a significant loss of income and momentum.

Fines Imposed by Tax Authorities

In addition to actions taken by the digital platform, tax authorities in EU member states can impose direct financial penalties for non-compliance. These fines are designed to be effective, proportionate, and dissuasive, ensuring that sellers and platform operators adhere to the DAC7 reporting framework.

Based on regulations in jurisdictions like Malta, a seller could face various fines, including:

Type of Non-Compliance	Example Penalty (Based on jurisdictions like Malta)
Failure to Retain Documentation	A penalty, such as €2,500, for not keeping required records.
Late Reporting	A one-time penalty for late filing, potentially combined with a daily penalty until the information is submitted.
Inaccurate Reporting	Significant fines for providing incomplete or incorrect information, which can reach up to €50,000 for major non-compliance.

Navigating these complex tax obligations to avoid such penalties can be challenging, especially for a content creator with international income. Consulting an international estate planning lawyer can provide crucial guidance on structuring assets and ensuring long-term compliance across borders.

Future Cross-Border Regulations & The Role of an International Estate Planning Lawyer

Upcoming Cross-Border Tax Reporting Regulations

The implementation of DAC7 signals a broader movement toward greater tax transparency and cooperation between countries. One key development is the automatic exchange of information, which allows EU tax authorities to share data about the income a content creator earns on any digital platform. This ensures that:

• Earnings are visible across borders
• It becomes harder for income to go undeclared

Furthermore, the DAC7 reporting framework establishes a legal basis for joint audits. This means that two or more countries can form a single audit team to examine a taxpayer’s financial activities. For a content creator with cross-border income, this increases the likelihood of:

• Scrutiny from multiple tax authorities working together
• Enhanced efforts to ensure compliance

The Importance of Consulting an International Estate Planning Lawyer

As tax authorities increase their cross-border collaboration, managing international income and assets becomes significantly more complex. Issues such as these require specialised knowledge to avoid costly errors and penalties:

• Determining tax residency
• Navigating double taxation agreements
• Structuring overseas business entities properly

Engaging an international estate planning lawyer is essential for any content creator with global assets or diverse income streams. These legal experts can provide critical guidance on:

• Structuring your worldwide wealth
• Managing the tax implications of living or working in different countries
• Ensuring long-term asset protection

With the new era of transparency under DAC7 reporting, their expertise is vital for maintaining compliance and securing your financial future.

Conclusion

The introduction of DAC7 reporting rules for 2025 requires every digital platform to report earnings, making income for any EU content creator highly visible to tax authorities. Understanding these new obligations, what is considered taxable income, and the significant penalties for non-compliance is now a critical aspect of managing your online business.

As these regulations increase cross-border tax complexities, consulting an expert is crucial for managing your global assets. Contact the specialists at PBL Law Group to see how our international estate planning lawyers can help structure your worldwide wealth and ensure long-term compliance.

Frequently Asked Questions