DAC7 and Enaa  – no reporting obligations 

What is DAC7? Council Directive (EU) 2021/514

DAC7 is a European directive transposed into the Slovenian ZDavP-2 (Articles 79.b–79.č).

  • Purpose: to increase transparency in business conducted via digital platforms.
  • Platform reporting operators must report to tax authorities on sellers who sell goods or services through their platform.

Who is a platform reporting operator?

A company that administratively enables a digital platform through which third parties (sellers) can sell goods/services directly to customers.

Examples: Amazon, eBay, Booking.com, Wolt (when third parties post and sale their own listings).

When is there no reporting obligation?

  • When a company sells on its website in its own name and for its own account only.
  • Suppliers sell goods to the company, and the company then sells to the customer.
  • The customer’s contract is always with the company (not the supplier).
  • In this case, suppliers are not platform users under DAC7.

Enaa business model

  • Suppliers (from Slovenia and abroad) deliver goods to us.
  • We sell the goods to the end customer in our own name and for our own account.
  • The customer’s contractual relationship is exclusively with us.

Therefore, our system is not a digital platform within the meaning of DAC7, but a classic online store with own-account sales.

Conclusion

  • Enaa is not a platform reporting operator under DAC7.
  • We are not obliged to report data on our suppliers.
  • Regular tax obligations (VAT, corporate income tax, etc.) remain unchanged.