The EU Commission has sent reasoned opinions to Belgium, Greece, Finland (Province of Åland), Italy and Poland asking them to notify the transposition of the Directive on administrative cooperation into national law. The Administrative Cooperation Directive provides for the automatic exchange of information between tax authorities from 1 January 2015.

The Administrative Cooperation Directive contains provisions that prevent Member States from refusing a request for information on the basis that a financial institution holds data. It sets deadlines for the transmission of spontaneous information (where tax evasion is suspected) and information on request. It also provides for common forms, computerised formats and standard procedures to improve the quality and speed of data transmitted between national authorities.

In the absence of a satisfactory response within two months, the Commission may refer these member states to the ECJ.