Regulation
DAC8 and CARF: reporting of crypto-assets
Updated: · Leutrim Miftaraj, FLIORE · Editorial standards · Deutsche Fassung
Short answer
DAC8 (Directive (EU) 2023/2226) requires crypto-asset service providers in the EU to report their users' data to tax authorities from reporting year 2026; the first exchange between states follows in 2027. Switzerland is implementing the equivalent OECD standard, CARF. Family offices should keep tax residences and TINs of all persons and structures holding crypto-assets complete and up to date.
What it is about
The automatic exchange of information on financial accounts (AEOI/CRS) hardly captured crypto-assets. The OECD therefore created the Crypto-Asset Reporting Framework (CARF). The EU incorporated it into its administrative cooperation law with Directive DAC8, extending it in places. The aim is the same transparency as for bank accounts: the tax authority in the state of residence learns which crypto transactions its taxpayers carried out through providers.
Timeline
| Area | Basis | Data collection from | First exchange |
|---|---|---|---|
| EU (Germany, Austria) | Directive (EU) 2023/2226 (DAC8) | 1 January 2026 | 2027 (by 30 September) |
| Switzerland | AEOI Act extended to crypto-assets (CARF) | Legal basis in force since 1 January 2026; application postponed | Not before 2027; partner states set separately |
Who reports what
Reporting obligations fall on crypto-asset service providers, such as exchanges, brokers and certain custodians. They report the identity, residence and tax identification number of users as well as aggregated information on exchanges against fiat currency, exchanges between crypto-assets and certain transfers. Where users are entities, controlling persons are also captured – similar to CRS.
Crypto-assets in self-custody without a provider do not trigger reporting by third parties. The family's tax obligations remain unaffected.
Preparing in the family office
- Record all persons and structures holding crypto-assets, including small holdings.
- Keep tax residences and TINs complete and current.
- Align the classification of structures for CRS and CARF so that self-certifications to providers are consistent.
- Document valuations, acquisition costs and transactions so that providers' reports match the family's own records.
- Clarify the tax treatment with advisers before discrepancies surface.
In FLIORE
FLIORE records crypto-assets as assets in consolidated wealth and keeps tax residences with TIN for every person and structure. The AEOI/CRS pre-check shows missing data before banks or providers ask for it.
At a glance
| EU basis | Directive (EU) 2023/2226 (DAC8) |
|---|---|
| International standard | OECD Crypto-Asset Reporting Framework (CARF) |
| Obliged to report | Crypto-asset service providers, not users themselves |
| Core data | Identity, residence, TIN, aggregated transactions |
Frequently asked questions
Must the family office itself report under DAC8?
Usually not. Reporting obligations fall on crypto-asset service providers. The family office must, however, provide complete self-certifications and should keep data consistent with CRS and tax returns.
Does DAC8 apply to Swiss families?
DAC8 applies to providers in the EU. If a Swiss family holds crypto-assets with an EU provider, that provider reports under DAC8; exchange with Switzerland follows the CARF and the partner states that are set.
Are stablecoins covered?
Yes, stablecoins are among the covered crypto-assets. DAC8 also covers e-money tokens and extends CRS to certain electronic money products.
What if a TIN is missing?
Providers must collect the TIN; if it is missing, restrictions on the client relationship can follow. For the family office this means recording TINs of all persons and structures early.
Sources
- Directive (EU) 2023/2226 (DAC8) – EUR-Lex
- OECD – Crypto-Asset Reporting Framework
- State Secretariat for International Finance (SIF) – AEOI on crypto-assets
This page provides orientation and does not replace legal or tax advice. The cited legal sources in their applicable version are authoritative.
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