The EU’s implementing regulation under DAC9 aims to enable automatic information exchange between Member States through technical solutions.
The European Commission has published the implementing regulation in the Official Journal of the EU Commission Implementing Regulation (EU) 2025/1325 of 7 July 2025, amending Implementing Regulation (EU) 2015/2378 as regards the standard forms and computerised formats to be used for the mandatory automatic exchange of information under Council Directive 2011/16/EU as amended by Council Directive (EU) 2025/872 on 17 July 2025.
The new Implementing Regulation establishes a common IT schema based on the one developed by the Organisation for Economic Co-operation and Development (OECD). This will ensure full interoperability between reporting under DAC9 and the OECD framework, thereby minimising the administrative burden on tax authorities and businesses alike.
This initiative aims to provide technical solutions to facilitate information sharing, supporting the implementation of the Pillar Two directive. The ultimate objective is to ensure that taxpayers comply with their obligations under the Pillar 2 Directive, while also minimising the administrative costs associated with tax compliance. The adoption of this Implementing Regulation confirms, once again, the strong commitment of all Member States to ensuring the seamless implementation of the Pillar 2 Directive.
This follows the Commission’s announcement on 7 July 2025 of the adoption of an implementing regulation under DAC9, which enables the automatic exchange of top-up tax information among EU Member States.
This regulation specifies the XML Schema format for mandatory information exchange under Article 8ae(5) and will take effect on 6 August 2025.
