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This schema establishes a standardised approach for the annual reporting of digital asset transactions and will be adopted under DAC8, which takes effect on 1 January 2026. Both regimes require crypto-asset service providers to document, validate, and report a range of information about their clients.
DAC8 serves as the EU counterpart to CARF, aiming to track digital asset transactions involving EU clients, both domestically and across borders. While DAC8 is broadly aligned with CARF, a key difference is its extraterritorial scope, covering certain transactions facilitated by non-EU intermediaries.
In the following sections, we will outline the key elements of the CARF/DAC8 XML schema, focusing on its structure, the role of reporting entities, and the specific transactional data that must be reported.
The main sections of a CARF or DAC8 annual report provide information on the following:
The Reporting Crypto-Asset Service Provider (RCASP), which can be either an individual or an entity. The RCASP is required to report their name, address, jurisdiction of tax residence, and tax ID. Also required is the reporting of its strongest nexus to the reporting jurisdiction, which can be one of seven values:
The last two nexus options are specific to DAC8 and do not apply to CARF.
The RCASP’s Crypto Users, which include both individuals and entities, as well as the reportable controlling persons of certain entities. The required information includes the name, address, jurisdiction(s) of tax residence, and tax ID(s).
For individuals, birth date must be reported, and for controlling persons of entity crypto users, their role in the entity must be reported as well (e.g., owner, senior managing official, settlor, trustee, protector, beneficiary, or other means of control).
The Relevant Transactions, detailing the reportable crypto-asset transactions conducted by users. For these transactions, the data to be reported includes:
Alternative valuation methods are allowed and must be specified as one of the following: book value, third-party value, recent RCASP valuation, or reasonable estimate by the RCASP.
Additionally, these transactions are reported in specific categories, listed below:
For crypto exchanges (i.e., Crypto to Crypto or Crypto to Fiat), the RCASP may optionally specify the type of transaction, such as: Staking, Crypto loan, Wrapping, or Collateral.
For crypto transfers, however, reporting the type of transaction is mandatory, with the following options:
DAC8 must be transposed into local law by each EU Member State by 31 December 2025. While some variations may arise in how each jurisdiction adopts the schema, it is generally expected to be applied uniformly across the EU.
In addition to the crypto-asset reporting schema, RCASPs that also operate in e-money may need to file additional returns under the Common Reporting Standard (CRS). Both CARF and DAC8 include amendments to CRS, such as classifying e-money and digital asset operators as Financial Institutions, with e-money accounts reportable under CRS.
We can assist financial institutions in implementing effective processes to ensure compliance with the new requirements as follows:
