Poland Moves to Implement DAC7, DAC8 and DAC9 Tax Rules

August 5, 2025

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On July 25, 2025, the Polish Ministry of Finance launched a public consultation on the Law, which proposes the introduction of several EU directives and OECD reporting rules and requirements related to the automatic exchange of information, commonly referred to as AEOI.

This action by the Ministry of Finance is a testimony to Poland's efforts to align with evolving international tax standards and strengthen administrative cooperation, reflecting the growing global focus on transparency in digital and cross-border transactions.

Measures Proposed by the Law

The law proposes the introduction of the mandatory automatic exchange of information under EU Pillar Two and implementation of reporting requirements under the OECD's Crypto-Asset Reporting Framework. More precisely, the Law proposes the transposition of the EU Council Directive 2021/514 on the AEOI for digital platform operators, known as the DAC7, and the EU Council Directive 2023/2226 on administrative cooperation in the field of taxation or DAC8.

Furthermore, the Law proposes the transposition of the EU Council Directive 2025/872 on a standardized digital format for information exchanges under Pillar Two, or DAC9. Additionally, the Law sets June 30 as the deadline for submitting the required data from the previous reporting year on crypto-asset users. The proposed effective date is January 1, 2026, whereas all key stakeholders have until August 18, 2025, to submit their comments and remarks on the proposed text of the Law.

In addition to this, the Ministry of Finance letter on public consultation also includes a reference to a request to the Department of European Union Law at the Chancellery of the Prime Minister to prepare an opinion on the draft's compliance with European Union law.

Conclusion

The implementation of DAC 7, DAC 8, and DAC 9 rules and regulations is only a question of formality. Once the public consultation is closed, it is to be expected that the proposed Law will be adopted and enacted. However, because the Department of European Union Law will need to provide its opinion on compliance with EU rules and regulations, the text of the law may be revised. Therefore, all affected parties should wait until the final version of the Law's text is published in the Official Gazette to confirm all critical dates.

Source: Bloomberg, Polish Ministry of Finance

What is the purpose of Poland's proposed tax law?

The proposed law aims to align Poland with international tax standards by introducing mandatory automatic exchange of information through EU directives DAC7, DAC8, and DAC9, as well as implementing the OECD's crypto-asset reporting rules.

Which EU directives are included in the proposed Polish law?

The proposed law includes the transposition of DAC7 (Directive 2021/514), DAC8 (Directive 2023/2226), and DAC9 (Directive 2025/872), covering digital platform reporting, crypto-asset user data, and standardized digital exchanges under EU Pillar Two.

When is the deadline for submitting crypto-asset user data?

According to the proposed law, the deadline for submitting crypto-asset user data from the previous reporting year is June 30.

What is the effective date of the proposed law in Poland?

The proposed effective date for the law’s implementation is January 1, 2026, pending final approval after the public consultation.

When does the public consultation on the law end?

Stakeholders have until August 18, 2025, to submit their comments and feedback on the proposed law during the public consultation phase.

Will the law be revised before becoming final?

It’s likely, as the Department of European Union Law must assess the law’s compliance with EU legislation, which may lead to revisions before its publication in the Official Gazette.

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