Compliance Briefing — January 31, 2025
With the 31 January 2025 DAC7 filing cut-off hours away, Zeph Tech is synchronising finance governance, universal opt-out handling, and evidence vaults so every EU platform report is defensible across tax, privacy, and audit reviews.
Executive briefing: Council Directive (EU) 2021/514 (DAC7) requires digital platform operators to file reports on reportable sellers’ 2024 activity with their competent tax authority by . Zeph Tech operates marketplaces for software subscriptions, professional services, and co-selling partnerships, so the company must submit jurisdiction-specific XML packages covering seller identity data, payment amounts, and property listings. The reporting team has spent the final week of January reconciling finance, legal, privacy, and engineering responsibilities to deliver filings that withstand validation checks, support universal opt-out obligations, and satisfy internal and external auditors. This 1,200-word guide summarises the controls that leadership expects to see in place before the deadline expires.
Regulatory scope and filing mechanics
DAC7 applies to EU-established platform operators as well as certain non-EU operators that facilitate relevant activities for EU sellers. The directive captures four activity classes: rental of immovable property, personal services, sale of goods, and rental of transport means. Zeph Tech’s compliance team mapped every marketplace product line to these categories, confirming which legal entities qualify as platform operators. Because Zeph Tech maintains subsidiaries in Ireland, Germany, and France, the company elected to report through Ireland’s Revenue Online Service (ROS) as its primary nexus while registering secondary presences in France and Germany to account for locally hosted sellers.
Reports must follow the XML schema published by the OECD (DAC7 schema v1.0) and include seller identifying information (name, address, TIN, date of birth for individuals), financial data (gross consideration, commissions, fees, and number of relevant activities), and property details for rentals. Zeph Tech has implemented automated schema validation using the open-source DAC7 XSD, ensuring that country codes align with ISO 3166, currency amounts use ISO 4217, and that optional fields are populated where required by national transpositions. The tax technology squad also configured secure API integrations with ROS and other member-state portals, rotating certificates according to NCA requirements and logging submission receipts for evidence.
Due diligence and seller lifecycle governance
Article 8ab of the Directive requires platform operators to perform due diligence on reportable sellers by verifying TINs, VAT numbers where relevant, and business registration data. Zeph Tech’s Seller Integrity Office manages this lifecycle using a risk-based workflow:
- Onboarding checks: At registration, sellers must complete digital know-your-customer (KYC) flows that capture identity documents, beneficial ownership declarations, and jurisdictional residency statements. Automated API calls validate TIN formats against EU national patterns, and manual review queues handle exceptions.
- Annual certification: Every Q4, sellers receive secure portal prompts to confirm or update their DAC7 information. Non-responsive sellers trigger escalation emails and account restrictions consistent with Article 8ab(3).
- Change monitoring: Integration with the customer data platform (CDP) ensures that any seller profile updates cascade into the DAC7 warehouse. Audit logs record who approved changes and whether universal opt-out preferences were adjusted in parallel.
The governance structure assigns accountability to the Chief Accounting Officer, with oversight from the Audit Committee. A DAC7 Steering Council—comprising tax, legal, privacy, data governance, and platform operations leaders—meets fortnightly to review readiness metrics. Minutes, decisions, and risk acceptance statements are stored in the GRC platform and linked to Jira workstreams for traceability.
Data architecture, controls, and universal opt-out alignment
Zeph Tech’s data engineering team built a dedicated DAC7 data mart that sources transactions from ERP systems, the payments processor, and the CDP. ETL pipelines cleanse addresses, convert currencies using the European Central Bank’s reference rates, and calculate gross consideration per seller. To ensure alignment with universal opt-out commitments, the pipelines consult Zeph Tech’s global preference orchestration service before loading personal data. If a seller has invoked a universal opt-out (for example through state-level registries, GDPR objections, or Zeph Tech’s own privacy dashboard), the system tags the record and routes it to legal review. Legal confirms whether the opt-out can be honoured while still meeting legal reporting obligations. DAC7 creates a statutory requirement that overrides deletion requests for data essential to the report, but Zeph Tech documents every decision explaining why the data must be retained and how it will be isolated from marketing or analytics processing.
Preference management logs feed into the evidence vault so that, if a seller questions why their information was reported despite an opt-out, Zeph Tech can demonstrate the legal basis under Article 6(1)(c) GDPR and the specific DAC7 duty. The company has also updated its privacy notices to clarify that universal opt-outs stop optional uses of data (targeted advertising, cross-context analytics) but do not supersede mandatory tax reporting.
Evidence expectations from tax authorities and auditors
Tax authorities commonly request proof of due diligence efforts, submission receipts, and correction workflows. Zeph Tech maintains a layered evidence repository:
- Due diligence dossiers: Each seller’s folder includes KYC outputs, TIN validation screenshots, communication history, and opt-out reconciliation notes. Files are sealed with cryptographic hashes to demonstrate integrity.
- Submission logs: Automated jobs archive XML payloads, acknowledgement messages, and error reports from ROS and other portals. A dashboard tracks which reports were accepted, rejected, or remain pending.
- Governance records: Meeting minutes, policy updates, and training completion lists show how the organisation enforced DAC7 obligations across teams.
- Correction procedures: SOPs describe how Zeph Tech issues corrected or supplemental reports within the one-month window mandated by Article 8ac(9). Evidence includes root-cause analyses and remediation actions.
Internal audit conducted a readiness assessment in December 2024, sampling seller files to confirm completeness and reviewing segregation-of-duties controls for data preparation versus submission approval. External auditors plan to rely on this work, so Zeph Tech has mapped each control to the relevant COSO component and stored testing artefacts for reuse.
Operational timeline for the final 72 hours
The operations centre follows a detailed timetable for the closing days before the deadline:
- January 29: Freeze DAC7 data pipelines, run variance analysis against prior drafts, and obtain final sign-off from tax and privacy leads that universal opt-out exceptions are documented.
- January 30: Execute dry-run submissions through ROS’s test environment, validate encryption certificates, and stage regulator contact matrices in case live support is needed.
- January 31 (morning): Deploy production XML files, monitor acknowledgements, and capture screenshots of submission confirmations.
- January 31 (afternoon): Hold a cross-functional stand-up to confirm all jurisdictions have responded, escalate any rejection messages, and determine whether corrected reports are necessary.
- Post-deadline: Publish an internal lessons-learned note, refresh training content, and schedule audits of sellers flagged for missing TINs.
Each step is logged in the incident-management platform to establish an audit trail. The COO and CFO receive hourly updates on submission status until all acknowledgements are confirmed.
Governance, risk, and compliance integration
The Audit Committee expects management to maintain risk registers capturing scenarios such as inaccurate seller classification, missing permanent establishments, or failure to respect universal opt-out commitments. Mitigations include automated validation scripts, human review gates, and escalation thresholds for legal disputes. Compliance also tracks regulatory developments: several member states have issued guidance that expands the definition of “platform” to include SaaS marketplaces and job-matching services. Zeph Tech’s legal team reviews these updates quarterly and adjusts the scope of reportable sellers accordingly.
Training programmes reached more than 600 employees in 2024, covering finance, customer success, engineering, and partner management. Training emphasised the interplay between DAC7, GDPR, and local consumer protection rules. Specialised modules explain how to handle universal opt-out requests from sellers while preserving evidence of compliance. Attendance records, knowledge-check scores, and policy acknowledgements sit in the evidence vault for regulator review.
Technology enablement and monitoring
Engineering has deployed alerting that detects anomalies in gross consideration figures, sudden spikes in new sellers from high-risk jurisdictions, and missing TIN ratios above tolerance. Alerts feed into the governance, risk, and compliance (GRC) platform, where case managers assign remediation tasks and document outcomes. Zeph Tech uses data quality tools to profile source systems and track lineage, so any late adjustments to ERP or billing data propagate transparently into the DAC7 mart. Change freezes prevent schema alterations during the reporting window.
A dedicated privacy engineering squad ensures that universal opt-out requests submitted via APIs, privacy dashboards, or authorised agent portals update both marketing suppression lists and regulatory reporting flags. The squad performs weekly reconciliations to confirm that opt-out tags match those stored in the DAC7 mart and that retention timers align with legal requirements.
Next steps after submission
After filings are accepted, Zeph Tech begins preparing for potential authority questions. The tax team drafts template responses explaining data sources, validation steps, and legal bases. Customer success teams receive briefing notes to address seller inquiries, emphasising the distinction between statutory reporting and discretionary data uses. The privacy office updates public FAQs to reinforce universal opt-out commitments and explain how sellers can review or correct their reported information.
The organisation also launches a 2025 enhancement roadmap. Objectives include integrating structured feedback from tax authorities, expanding automation for correction filings, deepening analytics that highlight sellers nearing reportable thresholds, and enhancing multilingual support for documentation. Lessons learned feed into the annual enterprise risk assessment and inform the 2025 budget request for tax technology and privacy engineering investments.
By synchronising governance, universal opt-out stewardship, and rigorous evidence management, Zeph Tech demonstrates that its DAC7 compliance programme can withstand regulatory scrutiny while maintaining trust with the seller community.
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