DAC9 is the ninth revision of the EU's Directive on Administrative Cooperation, and it does one specific job: it takes the OECD's GloBE Information Return and writes it into EU law as the official "top-up tax information return" required under Article 44 of the EU's Minimum Tax Directive. The Council adopted it in April 2025; member states were required to transpose it into domestic law by 31 December 2025.
What actually changes for a group with EU operations
Before DAC9, an MNE group with constituent entities in several EU member states faced a real risk of needing to satisfy each member state's own top-up tax information requirements separately, even where the underlying GloBE figures were identical. DAC9 closes that gap in two ways:
- Central filing. The group's UPE or a designated filing entity can file the GIR once, with the tax authority of a single member state, covering the whole group's EU footprint.
- Automatic exchange. That member state is then responsible for exchanging the relevant parts of the return with every other member state where the group has a constituent entity — the filer doesn't have to manage that distribution itself.
The first reporting deadline under DAC9 lines up with the global GIR deadline — 30 June 2026 for calendar-year groups, subject to the same portal-readiness extensions that affected the wider first filing season. Member states are then required to have completed the automatic exchange between themselves by 31 December 2026.
What DAC9 does not change
This is the point worth being precise about, because it's easy to over-read "central filing" as "central obligations." DAC9 governs the information return — the GIR itself. It does not touch:
- Local top-up tax liability returns and self-assessments under each member state's own QDMTT, IIR or UTPR legislation;
- Domestic notification deadlines, which in several member states fall earlier than the GIR deadline itself;
- Any jurisdiction-specific documentation a local tax authority is entitled to request independently of the exchanged GIR.
A group filing centrally under DAC9 still needs to track every member state's own top-up tax return cycle separately — the informational filing and the tax liability filing are not the same obligation, even though they draw on the same underlying computation.
Transposition is not uniform
The 31 December 2025 transposition deadline did not produce a clean, simultaneous rollout. Romania, for example, only transposed DAC9 into its Fiscal Procedure Code via Government Ordinance No. 1/2026 — after the nominal deadline had passed. Cyprus opened a public consultation on its own Pillar Two legislative amendments in mid-2026, partly to address European Commission observations and align more closely with OECD guidance. If your group has constituent entities in member states that transposed late or amended their implementation after the fact, it's worth re-checking the local mechanics rather than assuming DAC9 landed identically everywhere.
Practical steps
- Confirm which entity is your designated filing entity for DAC9 purposes, and in which member state it will file.
- List every EU member state where you have a constituent entity, and check that state's DAC9 transposition status rather than assuming it matches the directive text exactly.
- Separately track each member state's own top-up tax self-assessment and notification deadlines — these run independently of the DAC9 exchange timeline.
- Keep the full underlying GloBE computation and provenance trail available locally — the exchanged GIR does not relieve a constituent entity's own jurisdiction of the right to ask questions.
Pillar2OS tracks your entity footprint by jurisdiction and flags which obligations are covered by central GIR filing versus which local returns and notifications still need to be filed separately. Try it free.