The tax authorities are looking into Allegro and Vinted – DAC7 changes the rules for online sales

Publication date: November 02, 2026

Selling used items on Allegro, Vinted , or OLX, renting apartments through Booking.com or Airbnb, or even providing services via online platforms – all of these activities can now fall within the reach of the tax administration. The DAC7 directive does not introduce a new tax, but it does oblige digital platform operators to provide tax authorities with detailed information about transactions and their participants. We explain who is subject to these new obligations, what data is submitted to the tax authorities, and when reporting may trigger tax investigations or audits.

Introduction to DAC7 reporting obligations

The DAC7 directive introduces new reporting obligations for digital online platforms (e.g., Allegro, Vinted, Booking.com, Uber). These provisions directly apply to users who offer goods, services, or property rentals through these portals. This topic may be important for sellers and service providers, as information about their earnings will now be reported to tax offices, giving them a new tool for verifying the accuracy of tax settlements.

General principles of reporting obligations and basic concepts

In accordance with the regulations on the exchange of tax information, the reporting platform operator becomes the main information intermediary. The platform itself is defined as software, a mobile application, or a website that enables communication between users for the purpose of executing transactions and payment arrangements. Such an entity is obligated to collect, verify, and transmit data about its users to the tax authorities.

So-called relevant activities, i.e., specific activities performed for remuneration, are subject to reporting. The Act includes:

1. making real estate (or parts thereof and adjacent premises) available;
2. services provided in person (task-based or time-based work);
3. sale of goods;
4. providing means of transport.

Reports are submitted to the office periodically for a given reporting period, which according to the regulations is a full calendar year.

Scope of data transferred

Reports sent to the tax office are in the form of XML files and contain identification and financial information.

First, the operator provides information about themselves: name, primary address (i.e., registered office address), and identification numbers, including the Taxpayer Identification Number ( TIN , e.g., NIP or PESEL) and identification number. Next, the portal provides details of the seller, i.e., the registered platform user who has performed transactions on the platform in the specified year:

1. For individuals, the report includes: name, surname, date of birth, main address, TIN and VAT numbers.
2. If the sale is conducted by an entity (defined as a legal person, an entity without legal personality, a trust or e.g. a civil partnership), the report includes the full name, numbers in the relevant register (e.g. KRS), registered office address and information on foreign establishments.

The financial section summarizes user activity. It includes the financial account identifier (TIN). Furthermore, remuneration is reported, which the law defines as payment in any form, less contributions, fees, commissions, and taxes withheld by the platform itself. The list also includes the number of completed transactions broken down by quarter. In the case of property rentals, data is reported separately for each property group (properties at the same address and owned by the same person). The report then includes the address, land and mortgage register numbers, and the number of days the property was available.

Reportable entities

Whether information is submitted to the tax administration depends on the amount of turnover. The regulations use the concept of an active seller, which means a person who performs services or sells goods and is entitled to remuneration for such services in a given year.

However, there is a category of so-called excluded sellers, whose data is not transferred to the tax office. This exclusion applies only to the sale of goods.

and takes place when, during a calendar year, the user meets two conditions simultaneously:

1. completes less than 30 transactions,
2. his total remuneration in this respect will not exceed the equivalent of EUR 2,000.

Exceeding even one of these thresholds causes the user to become a reportable seller (an active seller without the right to opt out), which means that full information about his or her transactions is sent to the office.

Use of data by tax authorities

The Head of the National Revenue Administration (KAS) is required to submit the collected data to the authorities of the countries where the sellers are tax residents within two months of the end of the reporting year. If the case concerns property rentals, the information is also sent to the country where the building is located. Information about portals exempt from reporting is, in turn, sent to the European Commission’s central register.

In Poland, tax authorities use the Central Tax Data Register (CRDP), where this information is collected and compared with other declarations. KAS’s activities are based on automated data processing and risk analysis. This includes profiling, which can have direct legal consequences for taxpayers. Additionally, the authorities use this data to monitor online platforms for compliance with prudential procedures. The tax administration is required to retain this information for at least five years.

Actions taken by tax authorities

Analysis of incoming information allows the tax authorities to detect irregularities. The following signals are of greatest interest to the authorities:

1. Discrepancies with annual tax returns – algorithms automatically compare earnings reported by the platform with taxpayer declarations (PIT-36, PIT-37, PIT-28). High sales without reporting these earnings raise suspicions of income concealment and result in the initiation of investigations.
2. Scale of activity – regular sale of a large number of items by a person not registered in CEIDG suggests organized business activity, which involves the obligation to pay social security contributions and higher taxes.
3. VAT exemption limits – offices monitor whether the total revenues from various portals do not approach the amount of PLN 200,000 per year, exceeding which results in the obligation to register for VAT.
4. Intensive rentals – in the case of rentals (e.g., Booking.com, Airbnb), a high number of booking days (e.g., over 180 days) without declaring income is alarming. The office also verifies the address to ensure the property is not subject to the higher property tax rate for businesses.
5. Undisclosed accounts – the identification of accounts makes the authorities aware of the existence of foreign accounts or electronic wallets (Revolut, Wise) that have not been reported to the tax office, which is often interpreted as an attempt to conceal turnover.
6. Cost to revenue ratio – abnormally high fees and commissions relative to turnover may suggest artificially lowering the tax base.

Verification and control process

When the data raises doubts in the tax authorities’ minds, the authorities initiate appropriate procedures. The regulations explicitly allow the Head of the National Revenue Administration to demand that banks disclose transaction histories to verify the accuracy of the reports (bypassing banking secrecy in this respect).

During an audit, officials often analyze a number of documents from the taxpayer:

1. History of bank accounts and payment systems – private and corporate accounts, as well as PayPal and PayU.
2. Platform dashboards – to confirm cancelled transactions, refunds and actual fees charged that reduce the final turnover.
3. Proof of purchase – invoices, receipts, sales contracts – necessary to reduce income by incurred expenses.
4. Logistics documentation – waybills and parcel dispatch records to verify the scale of shipments.
5. Evidence of a private sale – the authority may examine screenshots or listing descriptions. The sale of private property is not subject to tax, but the taxpayer must prove possession of the sold item for at least six months.
6. Company registers (for entrepreneurs) – Revenue and Expenditure Book and VAT registers in terms of consistency of entries with the data sent via the platform.

Consequences of detecting irregularities

There are consequences for users whose failure to comply with the regulations is identified by the authorities. If, during verification or audit, the tax authorities determine that sales conducted via online platforms constituted a business activity, the taxpayer may be required to submit appropriate tax settlements and, depending on the circumstances, retroactively register the business. This may result in the obligation to pay outstanding social security contributions with interest, the loss of entitlement to certain preferences, and the need to settle tax arrears, including VAT (if the statutory requirements are met). If the tax liability is found to be understated, the authorities may apply tax penalties as specified in the regulations and initiate proceedings for fiscal criminal liability.

Moreover, concealing income or providing false information in a tax return constitutes a fiscal offense or misdemeanor, punishable by a fine of up to 720 daily rates. The same penalty applies to obstructing a tax audit (e.g., refusing to provide account statements).

Administrative penalties will also be imposed on sellers more quickly if they fail to complete their information on the platform itself. Failure to respond to the platform’s requests within 60 days will force the platform to immediately suspend payment and block the user from further sales.

Limitations of DAC7 Reports

In practice, DAC7 reports provide only a selective picture of a taxpayer’s situation, as they only report gross revenue without taking into account the costs of obtaining it, such as the purchase price of the goods or their preparation. This prevents authorities from automatically determining taxable income based solely on the XML file. DAC7 reports do not include information on the period of possession of the sold items, and therefore do not, in themselves, allow tax authorities to determine whether the sale of private property benefits from income tax exemption after six months of acquisition. Furthermore, the reporting thresholds for the sale of goods and the fact that each platform reports information separately mean that the data submitted under DAC7 may not reflect the taxpayer’s full activity. However, this does not mean that tax authorities are unable to obtain such information from other sources permitted by applicable law. Consequently, by failing to consider the taxpayer’s full situation, this information does not reflect the scale of their burden and serves solely as an analytical signal for selecting individuals for verification activities, rather than a ready-made basis for tax assessment without the seller’s involvement and explanation.

Practical tips for sellers

Risk mitigation associated with DAC7 reporting is based on the following principles:

1. Monitoring sales – it is worth monitoring the number of transactions and the value of sales on an ongoing basis, including the reporting exclusion thresholds provided for in DAC7 for the sale of goods (fewer than 30 transactions and remuneration not exceeding EUR 2,000), as well as limits resulting from other regulations, in particular those relating to unregistered activities and VAT.
2. Collecting evidence when selling in person – in order to avoid paying income tax on the sale of used items, you should collect evidence (receipts, contracts, emails with old orders) proving that the item has been in the seller’s possession for at least 6 months.
3. Cost recording – keeping a list and collecting proof of expenses: invoices for courier shipments, fees for promoting offers, contracts for the purchase of goods.
4. Data transparency – regular updating and verification of identifiers on sales portals: PESEL, NIP, address.