Four activities make a business a reporting platform operator, and personal services is broader than most operators assume. The excluded-seller thresholds have two limbs that both have to hold, and the data has to be collected at sign-up to be reportable by 31 January.
Who has to report, and about whom
Council Directive (EU) 2021/514 — DAC7 — added Annex V to the administrative cooperation directive and made digital platforms report their sellers to the tax authorities. Member States had to transpose it by 31 December 2022 and apply it from 1 January 2023, so the first reports are long since filed. The question that still catches businesses is whether they are a platform at all.
The trigger is a Relevant Activity carried out for consideration, and there are four:
the rental of immovable property — residential, commercial, any other immovable property, and parking spaces;
a personal service;
the sale of goods;
the rental of any mode of transport.
Activity carried out by a seller acting as an employee of the platform operator, or of a related entity, is not a Relevant Activity. Everything else that a platform facilitates for consideration is.
The sellers who drop out
A Reportable Seller is any active seller resident in a Member State, or who rented out immovable property located in one, other than an Excluded Seller. There are four kinds of excluded seller, and two of them are thresholds worth knowing:
governmental entities, and listed entities (or their related entities);
large property operators — where the platform facilitated more than 2,000 rentals of immovable property in respect of one property listing in the period;
small goods sellers — fewer than 30 sales of goods, with total consideration not exceeding EUR 2,000, in the period. Both limbs must hold: thirty-one small sales is reportable, and so is a single sale of EUR 2,500.
The deadline, and the one-report rule
The report goes to the competent authority no later than 31 January of the year following the calendar year in which the seller is identified as reportable. Consideration is reported net of fees, commissions and taxes withheld or charged by the platform.
Two provisions save duplicated work. Where more than one reporting platform operator exists, one is exempt if it holds proof, under national law, that the same information has been reported by the other. And an operator meeting the conditions in several Member States elects one of them and reports there.
Both are only as good as the evidence behind them: the exemption turns on proof that someone else reported, not on an assumption that they did.
Why it matters beyond the filing
DAC7 data is exchanged between tax authorities automatically. For the platform the obligation is administrative; for the sellers on it, the practical effect is that income facilitated through the platform is visible to the authority of their residence whether or not they declared it. Platforms discover this when sellers start asking what was reported about them, which is a conversation worth being ready for.
The due diligence sits with the platform too: identifying sellers, collecting and verifying the required information, and determining residence. That is a product and onboarding question before it is a tax one — the data has to be collected at sign-up to be reportable in January.
What to check
Whether what your platform facilitates is one of the four Relevant Activities — personal services is broader than most operators assume. Whether your onboarding actually collects what Annex V requires, rather than what the payment provider needs. Whether your excluded-seller logic tests both limbs of the goods threshold. And, if you operate across borders, which Member State you have elected and whether that election is recorded anywhere.
Registration duties, penalties and the reporting mechanics are set by the Latvian transposing law rather than by the Directive, and that is the part to confirm locally.