The deadline for submitting comments is 18 August 2025.

Poland’s Ministry of Finance initiated a consultation regarding Draft Bill No. UC110 on 25 July 2025. The bill focuses on implementing mandatory automatic exchange of information (AEOI) under Pillar Two and reporting obligations under the OECD’s Crypto-Asset Reporting Framework (CARF).

The key measures include:

  1. Implementing EU Council Directive 2021/514 (DAC7) for AEOI by digital platform operators.
  2. Implementing EU Council Directive 2023/2226 (DAC8) and CARF, expanding AEOI to include new digital payment methods.
  3. Implementing EU Council Directive 2025/872 (DAC9) on administrative cooperation in taxation.

Approved by the European Council in October 2023, DAC8 is based on the OECD’s Crypto-Asset Reporting Framework (CARF) and the updated Common Reporting Standard (CRS) for the automatic exchange of financial account information. This directive introduces new reporting and due diligence obligations for crypto-asset service providers. The European DAC8 Directive aims to increase transparency regarding crypto asset ownership, which will help combat tax avoidance and evasion more effectively. It also facilitates enhanced information exchange on cross-border rulings for high-net-worth individuals and sets penalties and compliance measures for reporting obligations.

DAC9 introduced new rules for sharing top-up tax information and implementing filing obligations under Directive (EU) 2022/2523 (Pillar Two Global Minimum Tax Directive). The new rules allow ultimate parent entities or designated filing entities of an MNE group to file the top-up tax information return under Directive (EU) 2022/2523. This removes the need for other constituent entities in different EU Member States to file separately. DAC9 also provides filing rules and a standard template for the return.

Poland, along with other EU Member States, is required to incorporate both directives into its legal framework by the close of 2025.

The public consultation will remain open for comments until 18 August 2025.