Tax transparency and sustainability: DAC6, SAF-T and the CSRD compared
Updated: 4 days ago
Note of 3 November 2026: in Romania, sustainability reporting under the CSRD now applies, from financial years beginning on 1 January 2027, to companies above both thresholds of RON 2,250,000,000 net turnover and an average of 1,000 employees (Order 1281/2026). See our article on Law 137/2025.
DAC6 (Council Directive (EU) 2018/822), SAF-T (Standard Audit File for Tax) and the CSRD (Corporate Sustainability Reporting Directive, Directive (EU) 2022/2464) are three distinct frameworks with different purposes, but all of them increase transparency in business operations.
How the three compare:
DAC6
Acronym:
DAC stands for the Directive on Administrative Cooperation in the field of taxation (Directive 2011/16/EU). DAC6 is the sixth amendment to it, made by Council Directive (EU) 2018/822.
Purpose:
To mandate the disclosure of cross-border tax arrangements that could potentially be used for aggressive tax planning.
Enhance tax transparency and enable tax authorities to take preventive or corrective action against tax evasion and avoidance.
Scope:
Applies to intermediaries (for example tax advisers, accountants and lawyers) and, in some cases, to taxpayers involved in cross-border arrangements.
Applies to arrangements that meet certain ‘hallmarks’ indicating potential tax avoidance.
Reporting Requirements:
Intermediaries or taxpayers must report certain cross-border arrangements to the tax authorities.
Reports are due within 30 days beginning on the day after the arrangement is made available for implementation, is ready for implementation, or the first step in its implementation is made, whichever occurs first.
Objective:
To provide tax authorities with early information about potentially aggressive tax planning strategies.
More details:
SAF-T
Acronym:
SAF-T stands for Standard Audit File for Tax, a format for the electronic transfer of accounting data from businesses to tax authorities, based on a standard published by the Organisation for Economic Co-operation and Development (OECD).
Purpose:
To facilitate the electronic exchange of accounting data between organisations and tax authorities.
Improve the efficiency and effectiveness of tax audits.
Scope:
Covers detailed financial and transactional data including general ledger entries, accounts payable and receivable, inventory, and fixed assets.
Reporting Requirements:
Companies must submit their accounting data in a standardised electronic format to tax authorities.
The frequency and content of SAF-T reporting vary by country. In Romania, SAF-T is filed as information return D406 (ANAF Order 1783/2021).
Objective:
To provide tax authorities with comprehensive and standardised accounting data for tax audits and verification.
More details:
CSRD
Acronym:
CSRD stands for the Corporate Sustainability Reporting Directive (Directive (EU) 2022/2464). It requires companies in scope to report on their environmental, social and governance (ESG) impacts and risks.
Purpose:
To disclose information on a company’s environmental, social, and governance (ESG) performance.
Enhance transparency about how companies impact and manage sustainability issues.
Scope:
Applies to the companies in scope under the directive and national law; the scope and timetable were amended after 2022, so check the rules in force for your financial year.
Covers a wide range of non-financial information, including environmental policies, social impact, diversity, human rights, and anti-corruption measures.
Reporting Requirements:
Companies in scope report under the European Sustainability Reporting Standards (ESRS) adopted by the European Commission. The CSRD replaced the reporting rules of the Non-Financial Reporting Directive (NFRD).
Objective:
To provide stakeholders, including investors, consumers, and regulators, with information about a company’s sustainability practices and impacts.
More details:
COMPARISON
Purpose and Focus:
DAC6: Tax transparency, focusing on potentially aggressive cross-border tax arrangements.
SAF-T: Accounting transparency, focusing on detailed accounting data for tax audits.
CSRD: Sustainability transparency, focusing on environmental, social, and governance impacts.
Scope:
DAC6: Cross-border tax arrangements.
SAF-T: Detailed financial and transactional data.
CSRD: Non-financial information on ESG factors.
Regulatory Requirements:
DAC6: Reporting specific tax arrangements within a set timeframe.
SAF-T: Submission of standardised accounting data, frequency varying by jurisdiction.
CSRD: Annual reporting on sustainability matters, under the ESRS.
Objective:
DAC6: To enable tax authorities to detect and prevent tax avoidance.
SAF-T: To support tax authorities in conducting efficient and effective tax audits.
CSRD: To inform stakeholders about a company’s sustainability practices and impacts.
Integration and Synergy
While each framework serves a different purpose, they collectively contribute to a holistic approach to transparency and accountability:
DAC6 ensures transparency in tax practices, helping to combat tax avoidance and evasion.
SAF-T gives tax authorities standardised accounting data for analysis and audits.
CSR offers insight into the broader impact of a company’s operations, aligning financial transparency with ethical and sustainable practices.
Together, they shape how companies document and disclose their tax and sustainability information.
Last updated: 3 November 2026 (CSRD acronym and references corrected). This article is for information only and does not replace an analysis of your specific situation. Updated with AI assistance; references were verified against the primary sources.
