EBF position on the proposed recast of the Directive on Administrative Cooperation in taxation

EBF position on the proposed recast of the Directive on Administrative Cooperation in taxation

Brussels, 27 October 2026 – The European Banking Federation (EBF) has published its position paper on the European Commission’s proposal, issued on 24 June 2026, to recast the Directive on Administrative Cooperation in the field of taxation (DAC).

The EBF welcomes the Commission’s efforts to consolidate the existing framework and simplify tax reporting obligations. We support measures that reduce duplicate reporting, remove low-value obligations and provide greater legal clarity, while preserving effective tax transparency. However, further improvements are needed to ensure that the Recast delivers meaningful simplification in practice and reduces the cumulative compliance burden on reporting financial institutions. 

A key priority is to ensure that the revised framework is proportionate and workable for financial institutions. We call for a clearer and more practical Pillar Two carve-out under DAC6, appropriate safeguards for regulated financial institutions providing routine services, and stronger protections against overlapping national reporting requirements and gold-plating. We also emphasise the need for effective centralised DAC4/DAC9 notifications, a practical TIN verification tool and a technology-neutral approach to avoid duplicate reporting of traditional financial instruments under DAC2 and DAC8. 

Finally, the EBF stresses that simplification should be measured by the elimination of duplicate data collection, unnecessary system changes and divergent national requirements. Clear rules, harmonised implementation and sufficient legal certainty are essential to reduce operational burdens for financial institutions and support a more consistent and efficient EU tax reporting framework.

Read the full document here

For more information:

Roger Kaiser, Head of Tax and Compliance – r.kaiser@ebf.eu

Giulia Verde, Policy Adviser/Executive Coordinator, Tax and Compliance – g.verde@ebf.eu

Anna Maria Nowak, Policy Advisor – Tax and Compliance – am.nowak@ebf.eu

About the EBF:

The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The federation is committed to a thriving European economy that is underpinned by a stable, secure, and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.