.avif)
With the reporting deadline approaching, the Belastingdienst has released its manual portal for DAC7 submissions. For platforms with a very small user base, this is a welcome, cost-free utility.
But before you commit your compliance team to this route, you need to look at the math. While the portal is free to access, it comes with a hidden operational cost that scales dangerously fast.
Here is the reality check on whether the manual portal is actually feasible for your business.
The 20-Seller Efficiency Threshold: Why "Free" Isn't Free
The most critical limitation of the manual portal isn't technical—it's operational. While there is no hard "cap" on how many sellers you can enter, the diminishing returns hit quickly.
The Hidden Math of Manual Entry: According to the workflow described in the user manual, entering a single seller involves creating a "Return List," verifying their details, and manually keying in separate financial activities.
- Time per Seller: ~5 to 7 minutes (including cross-checking TINs and addresses).
- The Impact: If you have 20 sellers, this is a manageable 2-hour task.
- The Scaling Trap: If you have 100 sellers, you are looking at a full workday (8+ hours) of non-stop data entry.
And that is just for entry. It excludes the time needed to fix errors if the Belastingdienst rejects a batch, which forces you to start over.
The 40% Trap: What the Portal Misses
The second reason to hesitate is that the manual portal only solves one-third of your actual compliance problem.
DAC7 compliance consists of three distinct pillars: Collection (Due Diligence), Submission (Reporting), and Notification (Statements). The manual portal only handles Pillar 2, leaving roughly 60% of the workload on your plate.
Pillar 1: Seller Due Diligence (Missed)
DAC7 requires you to collect and verify specific data (TIN, VAT ID, Date of Birth) before reporting.
- The Gap: The portal is just a passive form. It does not email your sellers to ask for data. It does not validate if a German Tax ID is correct.
- Your Burden: You must build your own "KYC" process to chase sellers and verify documents manually. If you type unverified data into the portal, you are liable for the errors.
Pillar 2: Reporting (Covered, but Limited)
This is the only part the portal handles—submitting the data to the tax authority.
Pillar 3: Seller Notification (Missed)
Under DAC7 Article 8ac, you are legally required to provide every seller with a formal PDF statement of their reported earnings by January 31st.
- The Gap: The portal is inbound-only. It collects data for the government but does not generate statements for your users.
- Your Burden: After spending a day typing data into the portal, you must manually create hundreds of secure PDF statements and email them to your sellers yourself.
Technical Deep Dive: How the Manual Workflow Actually Works
If you decide you fall under the "20-seller threshold" and want to proceed manually, it is vital to understand the specific workflow constraints detailed in the 2026 User Manual.
1. The "Return List" Structure
You don't just "add sellers." You must first create a "Return List". This acts as a container for a batch of sellers. If you have different types of sellers (e.g., rentals vs. services), you have to manage them in organized lists manually.
2. The "Activity" Granularity
The manual specifies (Section 3.1.3) that you must navigate to "Add Activity" separately for each seller.
- The Reality: You enter the seller's personal details and then separately enter their financial activity. If a seller had multiple types of income or operated in multiple quarters, these are distinct data points that must be keyed in individually, multiplying the clicks required per seller.
3. Critical Nuance: Overseas Territories
The manual highlights a common compliance tripwire regarding jurisdiction (Appendix 1).
- The Rule: If a seller is in Bonaire, Saba, or Sint Eustatius (the BES islands), you cannot select "Netherlands." You must specifically select "Netherlands Antilles".
- The Risk: Subtle distinctions like this are major manual entry risks. Selecting the wrong jurisdiction can lead to validation errors later, rejecting your entire Return List.
Summary: When to Automate
Stick to the Manual Portal if:
- You have fewer than 20 reportable sellers.
- You personally know your sellers and have already manually verified their Tax IDs.
- You have the internal resources to manually create and send PDF statements to your sellers.
Switch to Automation (S2S) if:
- You have 20+ Sellers: The manual data entry cost now outweighs the cost of software.
- You need Due Diligence: You want GetSupplied to automatically collect and validate Tax IDs via API.
- You need Seller Statements: You want GetSupplied to automatically generate and email the required Article 8ac statements to your users.
At Supplied, we provide a full-cycle solution; Data collection and Validation, Notifications and Earnings statements, Report Generation, Corrections & Submissions, in a single automated workflow.
You can find out more about our Automated DAC7 product here or feel free to Contact Us
