DAC6 reporting is mandatory, and getting it wrong can be costly. With enforcement ramping up across the EU, tighter audit scrutiny, and 30-day deadlines that leave no room for delay, fund managers face real financial and reputational risk if reportable arrangements go unflagged.
fundcraft’s DAC6 Transaction Reportability Assessment Tool helps fund managers identify potential disclosure obligations in under five minutes. The tool is fully automated and available at no cost.
What is DAC6—and why does it matter?
DAC6 (Directive 2018/822) is part of the EU’s Mandatory Disclosure Regime. It requires certain cross-border arrangements (CBAs) to be reported to national tax authorities—particularly those that may provide a tax advantage or meet specific “hallmarks.”
The obligation applies to a broad range of intermediaries, including fund managers, Alternative Investment Fund Managers, administrators, and, in some cases, any party involved in designing, marketing or managing the arrangement. If the main intermediary is unable to report, due to legal privilege or being based outside the EU, responsibility may shift to another party. In Luxembourg, both fund managers and administrators can be designated as primary or secondary reporters.
Despite its scope, many still underestimate DAC6’s impact. Enforcement is ramping up across Europe, tax audits are becoming more stringent, and the 30-day reporting window leaves little room for error. The cost of non-compliance is high: penalties range from €5,000 to €1 million per missed or late submission—up to €250,000 in Luxembourg and €5 million in Poland for severe breaches.
If your fund involves cross-border elements, DAC6 likely applies.
Where DAC6 gets complicated—and potentially costly
The biggest challenge lies in determining whether a specific arrangement is reportable. Some hallmarks—such as confidentiality clauses or standardised documentation—automatically trigger a disclosure. Others rely on the “main benefit test,” which assesses whether obtaining a tax advantage is a primary driver of the arrangement.
This complexity creates three types of risk for fund managers:
* Under-reporting, which can lead to fines or reputational damage
* Over-reporting, which may invite unnecessary audits
* Delayed reporting, increasing legal exposure and operational cost
Yet the outcome is binary: your transaction/arrangement is either reportable or it isn’t. And accuracy is critical—because mistakes are costly.
How fundcraft’s DAC6 tool is different
Most traditional providers, such as law firms and tax advisers, still charge for DAC6 assessments. Yet in many cases, the logic is structured, rules-based, and repeatable. The result is not just added cost; it also leads to slower delivery and limited clarity for fund managers who need fast, actionable answers.
At fundcraft, we believe compliance processes like DAC6 shouldn’t be locked behind billable hours. That’s why we built a better approach. Our DAC6 Transaction Reportability Assessment Tool is a fully automated, self-service, and completely free-of-charge solution.
How it works:
* Users complete a brief, structured questionnaire about their fund’s cross-border arrangements.
* The tool evaluates inputs against DAC6 hallmarks, based on applicable EU regulatory guidance.
* Users receive a summary indicating whether the transaction/arrangement needs to be reported.
Whilst this tool is not a substitute for legal advice, it enables fund managers to triage potential exposure early, allowing them to act decisively and direct legal input where it is most needed.
Who should use this assessment tool?
The tool was developed using materials and interpretative guidance from an accredited Luxembourg-based tax adviser. While grounded in Luxembourg’s approach to DAC6, the underlying logic is broadly consistent with EU-wide standards. It is particularly useful for Private Equity, Venture Capital and Fund-of-Funds managers with cross-border structures or multinational LPs.
You should consider running an assessment if your fund includes:
* Non-EU investors or counterparties
* Intra-group service agreements
* Multi-jurisdictional tax elements
* Confidentiality clauses or standardised legal templates
Even if you’ve never submitted a DAC6 report, your structure may still fall within scope. And exemptions are limited—meaning liability can shift quickly.
Start your DAC6 assessment—free and fast
Do not wait for an audit request to understand your disclosure obligations. The best time to evaluate DAC6 reportability is before it becomes a compliance risk.
With fundcraft, you can complete your assessment in minutes. If your arrangement is reportable, you’ll be ready to act. If it’s not, you’ll have a documented record supporting your due diligence.