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DAC7/Digital Platform Operators Regulations – for Agencies and Property Managers only – NEW October 2025

Introduction

This guidance sheet provides an overview of the DAC7 / Digital Platform Operators Regulations, designed to help digital platforms understand their reporting obligations under UK law. It outlines which platforms and services fall within scope, what is excluded, and the responsibilities of Platform Operators—including registration, data collection, annual reporting, and record-keeping. The guidance also highlights potential penalties for non-compliance and offers links to official HMRC resources for further support.

Scope

A Digital Platform is any software, website or application that is accessible by users (customers) and allows those users to connect (directly or indirectly) to Sellers for the provision of certain services.

A Seller can be an individual or an entity and is a Platform user (not employed by the platform) that is providing goods or services via the Platform and receiving income for those services through the Platform.

The Platform Operator (the one with the responsibility under the regulations) is the legal entity that contracts with the Sellers.

The Services in scope (and some examples of the larger platforms who fit that model):

Rental of Immoveable Property – holiday lets, parking spaces, storage units, static caravans/boats etc – eg AirBnB, Vrbo, JustPark

Sale of Goods – this means tangible goods via an online marketplace – eg Ebay, Etsy, Vinted

Transportation Rental – vehicles without a driver, cars, vans, boats, scooters etc – eg Turo, Getaround, Borrow A Boat

Personal Services – this is a wide range of activities covering any time or task based work at the request of a user – vehicles with a driver, deliveries, cleaners, gardeners, hairdressers, massage therapists, accountants, chefs etc – eg Deliveroo, TaskRabbit, Uber

What is Not in Scope?

Sole Traders – if you are running such a platform as a sole trader, then you are not in scope.

Listing Services – if your website merely advertises such services and then passes the user onto a different platform or company to make the booking/sale, then you are not in scope.

Software Only – technology providers who build platform tech but do not run the business it is built for are out of scope.

Selling Your Own Goods and Services – if your platform runs in the way described above, except that all the goods or services are your own, rather than provided by third party Sellers, then you are not in scope.  So, if you personally own all the properties being rented on your platform, you do not have a reporting requirement.

What Do Platform Operators Have To Do?
  • Register as a Platform Operator with HMRC
  • Collect and validate Due Diligence data from Sellers (personal details, bank details, property information and tax information)
  • Make an annual return of information to HMRC including the due diligence data plus information about income paid and fees and taxes applied by the Platform – by Jan 31st each year, for the previous calendar year of data
  • Provide Sellers with statements of what has been reported about them
  • Keep records for a minimum of 5 years
What If I Don’t Do These Things?

HMRC have not been great at communicating these new rules to platforms, but they have been quite generous with the amount of time given to get ready.

Anyone who has made best efforts to get their new policy and procedures in place by the end of this year, and submits a timely and accurate return in January 2026, should not see any penalties for being late to the game.

From January 2026 we expect HMRC to be much stricter on reviewing compliance from Platforms and issuing penalties where appropriate.

The penalties:
  • up to £1,000 for not registering correctly on the HMRC portal
  • up to £5,000 + an additional £600 per day of lateness on submitting annual returns or providing Seller statements
  • up to £100 per Seller for not applying due diligence procedures correctly
  • up to £100 per Seller for incomplete or inaccurate reports
  • up to £5000 per year for not keeping records correctly
Other Things To Note

These are international regulations, live in the EU, Canada, New Zealand and more countries adding all the time.  When you do your scoping exercise, especially if you rent properties in the EU, make sure you understand all your international as well as UK requirements.

You may have to report more than one activity on your books, especially if you are a property rental platform that offers supporting experiences and services.

Reporting is in XML format with a very specific schema – make sure you plan ahead as purpose built tech will be needed to produce these files.

For your own information, you can find the Platform Operators Regulations here: https://www.legislation.gov.uk/uksi/2023/817/contents

And the HMRC technical guidance: https://www.gov.uk/hmrc-internal-manuals/international-exchange-of-information/ieim900000

Other Useful HMRC Links:

Register as a Digital Platform Operator: https://www.gov.uk/guidance/register-to-carry-out-digital-platform-reporting

Once registered, use this page to sign in and manage your reporting: https://www.gov.uk/guidance/manage-your-digital-platform-reporting

The technical specifications for XML reports, if you are building your own reporting tools: https://www.gov.uk/guidance/create-a-digital-platform-report

If you need to contact HMRC regarding lateness, technical difficulties or anything to do with reporting, use this email address:  aeoi.enquiries@hmrc.gov.uk

Information for Sellers

When requesting the Due Diligence information from your owners, you can provide them with this HMRC link which explains what information they are being asked for and why:

https://www.gov.uk/guidance/selling-goods-or-services-on-a-digital-platform

If they are not sure if they have to declare their rental income to HMRC, this free tool can help them check their situation:

https://www.gov.uk/guidance/check-if-you-need-to-tell-hmrc-about-your-income-from-online-platforms

Remember that you will also be sending each reported Seller a statement of everything that has been reported about them annually, so they can use that to help fill in their tax returns accurately.

 

Author of guidance: Natalie Dowling, Head of Tax Platform, Hartford Consulting natalie.dowling@hartfordconsultants.co.uk

Date of guidance: October 2025

Version Number: V1

Disclaimer – Guidance Sheets are written by experienced Members of the ASSC and other experts. The information in the ‘Guidance Sheet’ is provided by the ASSC for use by Members in support of their own independent business decisions. It does not constitute advice or instruction for which the ASSC can be held liable in any way whatsoever. All Members and other readers remain responsible for the consequences of any decisions taken whether in the light of information gained from this Guidance Sheet or not.

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