Sweden Approves DAC9 Rules, Accelerating Pillar Two Reporting Exchange

Sweden’s parliament approved DAC9-implementing legislation on May 7, adding another hard deadline to a Pillar Two process that has moved from theory into daily compliance work. For KPMG tax teams, the immediate issue is not the policy signal but the operational squeeze: one central GloBE return now has to be accurate enough to move automatically across tax authorities, which means cleaner handoffs between local controllers, global tax leads, legal entity owners and external advisers.

The new Swedish rules are built around the EU’s DAC9 framework, which is meant to let multinational groups file one top-up tax information return centrally instead of repeating the same package across multiple jurisdictions. That may reduce duplication on paper, but it also raises the cost of bad data. The first top-up tax information return is due by June 30, 2026, and tax authorities must exchange that information by December 31, 2026. In Sweden, most DAC9 provisions take effect on May 1, 2026, while amendments to secrecy rules begin on August 1, 2026, so the calendar is moving faster than many client teams can comfortably absorb.

That matters because Sweden is not starting Pillar Two from scratch. The country already brought the broader regime into domestic law effective January 1, 2024. The income inclusion rule applies for accounting periods beginning on or after January 1, 2024, and the undertaxed profits rule applies for periods beginning on or after January 1, 2025. DAC9 adds the reporting-and-exchange layer on top of an already live minimum-tax system, which means Swedish groups and foreign groups with Swedish entities now have to prove that their numbers, entity mapping and jurisdiction-by-jurisdiction reviews can survive automatic exchange.

The rework risk sits where local accounting data meets the central filing. A weak reconciliation can ripple into deferred tax calculations, disclosure planning and local-language filings, especially when the same data has to satisfy both the central return and local secrecy or confidentiality rules. That creates immediate demand for implementation support, data-quality remediation and filing-readiness work across borders, not just inside a single tax function.

The Swedish Ministry of Finance submitted bill 2025/26:102 on January 27, 2026, after a consultation that ran from July 4 to October 6, 2025. The European Economic and Social Committee welcomed DAC9 as part of the OECD/G20 Inclusive Framework’s broader overhaul of international tax rules, but warned that the information should be used only for its intended purpose and noted the absence of an impact assessment and competitiveness check. Over 135 jurisdictions joined the 2021 agreement, and the direction of travel is now clear: Pillar Two is becoming more connected, more automatic and less forgiving of sloppy preparation.