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DAC8

Directive on Administrative Cooperation (tax transparency for crypto-assets)

DAC8

DAC8 provides for automatic exchange of information on crypto-assets between EU countries. It is the eighth amendment of the Directive on Administrative Cooperation in Direct Taxation. 

The Directive aims to strengthen the overall legal framework on the automatic exchange of information (AEOI) to fight tax fraud and combat tax evasion and tax avoidance by enlarging its scope to cover crypto-assets.

DAC8 rules enter into force on 1 January 2026, expanding tax transparency to crypto-asset transactions. Reporting Crypto-Asset Service Providers should begin preparing now:

  • Single registration in the Member State if you operate in the EU but are not authorised under MiCA.
  • Start collecting data on reportable crypto-asset transactions of EU-resident users from 1 January 2026.
  • Reporting is due within 9 months after the end of the first fiscal year covered by the directive – that is between 1 January and 30 September 2027.
  • Check domestic requirements including reporting deadlines and formats.

More information

Rationale

The decentralised nature of crypto-assets has made it difficult for EU countries’ tax administrations to ensure tax compliance. The inherent cross-border nature of crypto-assets requires strong international administrative cooperation to ensure effective tax assessment and collection of the related income and capital gains. 

The Directive lays down the rules and procedures for exchanging information on crypto-asset users by implementing due diligence procedures and reporting rules for operators active in crypto-asset transactions and their users. The rules are based on the OECD's international standard Crypto-Asset Reporting Framework (CARF). 

Background

The directive was adopted by EU countries on 17 October 2023 and published in the Official Journal of 24 October. EU countries will have to transpose it by 31 December 2025 and must apply its provisions as of 1 January 2026. The first reporting year is 2026. 

The crypto-asset market has grown in importance as it provides a variety of new business opportunities, including those for innovation and investment. Nevertheless, the growth in the use of crypto-assets should not be at the expense of transparency for tax purposes. 

The decentralised nature of crypto-assets makes it difficult for EU countries’ tax administrations to ensure compliance with the rules and guidance they have put in place to tax income and gains derived from crypto-asset transactions. 

The directive requires EU countries to obtain information from the Reporting Crypto-Asset Service Providers (RCASPs) and exchange that information with the EU country of residence of the taxpayer/investor on an annual basis. 

Reporting

RCASPs are required to collect information pertaining to transactions of their non-resident investors for the reporting year according to the customer due-diligence obligations of the directive. 

This information is sent by RCAS to their national tax authorities in the calendar year following the reporting year. The information is then exchanged with tax authorities of the EU country of residence of the non-resident investor within 9 months of the reporting year. Therefore, the exchanges relating to the first reporting year will take place by 30 September 2027. 

Scope

This directive covers a broad scope of crypto-assets, building on the definitions set out in the European Crypto-Assets Regulation (MiCA). 

In addition, crypto-assets that have been issued in a decentralised manner, as well as stablecoins, including e-money tokens and certain non-fungible tokens (NFTs), are included within the scope of the directive. 

International impact

To address the risks posed by crypto-assets with respect to tax transparency, the OECD, in collaboration with G20 countries, completed and published the crypto-asset reporting framework (CARF) in July 2013. This framework provides for the reporting and automatic exchange of information (AEOI) related to crypto-assets between tax authorities for tax compliance purposes. 

G20 leaders immediately welcomed the development and invited the Global Forum on Transparency and Exchange of Information for Tax Purposes to support the rapid and widespread implementation of the CARF. 

As of July 2024, 58 Global Forum members (and growing) have already announced their intention to commence exchanges under CARF in 2027. This means that the automatic exchange of information on crypto-assets will combat tax evasion and tax avoidance on a global level. 

Legal texts

Council Directive (EU) 2023/2226 of 17 October 2023 amending Directive 2011/16/EU on administrative cooperation in the field of taxation 

Commission Implementing Regulation (EU) 2025/2263 of 12 November 2025 amending Implementing Regulation (EU) 2015/2378 as regards the standard forms and computerised formats for the mandatory automatic exchange of information on reportable crypto-assets, the communication of the yearly assessment and the list of statistical data to be provided by Member States under Council Directive 2011/16/EU