DAC8 and CARF in Belgium and the Netherlands: 2026 Guide

From 1 January 2026, Crypto-Asset Service Providers (CASP) must start collecting information under new reporting rules designed to improve tax transparency.

DAC8 covers the exchange of information within the EU, while the OECD’s Crypto-Asset Reporting Framework (CARF) supports information exchange with participating jurisdictions outside the EU.

For providers operating in Belgium or the Netherlands, the key questions are:

• Who must report?
• What information must be collected?
• How and when it must be submitted?

This guide outlines the main DAC8 and CARF requirements in both countries, highlights the practical differences, and explains what providers should prepare for as the first reporting deadline approaches.

Why DAC8 and CARF Matter

DAC8 and CARF introduce a more structured approach to tax reporting for crypto-assets. Reporting crypto-asset service providers must identify reportable users, carry out due diligence, collect the required customer and transaction information, and submit it to the relevant tax authority. The information can then be exchanged with the tax authorities in the jurisdictions where users are tax-resident.

Both frameworks apply to information collected from 1 January 2026, with the first reports due in 2027. The precise registration, filing and technical requirements depend on the country in which a provider is required to report.

Who Falls Within Scope?

The rules generally cover providers authorised under the EU Markets in Crypto-Assets Regulation (MiCA), as well as certain crypto-asset operators that provide relevant services without a MiCA authorisation. The central question is whether the business provides crypto-asset services that result in exchange transactions for reportable users. Providers should assess their activities and reporting obligations rather than assume that every crypto-related business is automatically in scope.

Core obligations include carrying out customer due diligence, collecting identifying details and reportable transaction information, filing with the relevant tax authority, and informing customers about the information reported. Depending on the services and products offered, providers may also need to consider the related Common Reporting Standard (CRS) and DAC2 rules, including reporting obligations for certain crypto-related financial products.

Belgium: Rules, Registration and Filing

Belgium signed the CARF Multilateral Competent Authority Agreement on 26 November 2024. Its law implementing DAC8 and related crypto-asset reporting obligations was dated 16 March 2026 and published in the Belgian Official Gazette on 1 April 2026.

Reporting crypto-asset service providers must complete the required due-diligence procedures, collect the relevant information for each reportable user, and submit it to the Federal Public Service (FPS) Finance. FPS Finance can then exchange the information automatically with the tax authority in the jurisdiction where the reportable user is tax-resident.

Providers that qualify as reporting crypto-asset operators but do not hold a MiCA authorisation may need to register with the Belgian competent authority, unless they have already registered in another EU Member State for these reporting obligations.

Belgian reports must be prepared in CARF–DAC8 XML format and submitted through MyMinfin. The files must follow the applicable OECD, EU and Belgian technical rules and validation requirements. FPS Finance has published guidance on XML creation and submission, while its dedicated web tool for generating XML files has been described as under development. Providers should check the official guidance for the latest specifications before filing.

The Netherlands: Scope, Data and Deadlines

The Netherlands applies DAC8/CARF from 1 January 2026. Providers must collect and verify the required customer and transaction information from that date, with the first report covering the 2026 calendar year due to the Dutch Tax and Customs Administration (Belastingdienst) by 31 January 2027.

As in Belgium, DAC8 provides for information exchange within the EU, while CARF supports exchange with participating jurisdictions outside the EU. Dutch guidance also highlights the relationship with CRS and DAC2. Depending on the services and products involved, certain crypto-derivatives and specified e-money products may trigger additional balance-reporting requirements.

The Dutch Tax and Customs Administration uses reported information to support tax oversight and help check whether taxpayers have correctly reported their crypto-assets. Providers should follow the current technical documentation and implementation updates published by the administration, as reporting specifications and technical services continue to develop.

What Information Must be Reported in the Netherlands?

The information to collect and report includes, where applicable:

• Customer details, including full name, address, tax residence and tax identification number.
• Crypto-asset exchange transactions, including the type of asset and transaction, number of units, gross amount and fair market value.
• Relevant transfers, including the type of crypto-asset and transfer, the value, and the number of transfers.
• Certain transfers to wallets where the provider cannot determine whether the wallet is held with another crypto-asset service provider, and qualifying retail payment transactions above the applicable threshold.

The Dutch tax authority can exchange reportable information with the relevant tax authorities in users’ jurisdictions of tax residence. Providers should consult the latest official guidance to confirm the exact data fields and reporting treatment applicable to their activities.

Deadlines & Practical Support in the Netherlands

Providers must retain the required information from 1 January 2026. The first annual report, covering 2026, is due by 31 January 2027. Customers must also be informed about the information reported to the Dutch Tax and Customs Administration by the applicable deadline. Providers can choose the form of notification, provided it meets the requirements.

Technical guidance and implementation updates are published through the Tax Administration’s digital reporting support website. Providers and software developers should check these resources regularly for the latest manuals, specifications, validation tools and release notes.

For questions about reporting scope or required data, providers can contact the Dutch Tax and Customs Administration at dac8@belastingdienst.nl. For technical reporting questions, consult the relevant guidance and contact details published by the Administration. For legal interpretation, seek advice from a qualified tax adviser.

Need professional support with DAC8 compliance or crypto taxation? O2K.tech provides professional tax consulting and advisory services to help businesses navigate their tax obligations with greater clarity and confidence. Contact our team at info@o2k.tech to discuss how we can support your needs.

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What should CASPS do now?

1. Assess whether your business qualifies as a reporting crypto-asset service provider or operator.
2. Review customer due-diligence processes and ensure you can collect and verify the required tax-residence and identification details.
3. Check whether your services or products also trigger CRS or DAC2 reporting obligations.
4. If you operate in Belgium, confirm whether registration is required and prepare for CARF–DAC8 XML reporting through MyMinfin.
5. If you report in the Netherlands, ensure your systems capture the required data from 1 January 2026 and prepare to submit the first report by 31 January 2027.
6. Monitor official guidance and technical updates in both countries, as reporting specifications and tools may change.

Conclusion

DAC8 and CARF make customer due diligence and crypto-transaction reporting a practical compliance priority for providers in Belgium and the Netherlands. Start by confirming whether your business is in scope, reviewing your data collection processes, and following the latest national filing guidance. Early preparation will help reduce errors and avoid last-minute reporting issues.

Official References and Further guidance

• ‍European Commission: DAC8 overview and reporting timeline‍
• FPS Finance Belgium: CARF–DAC8 guidance‍
• FPS Finance Belgium: Creating CARF–DAC8 XML files‍
• FPS Finance Belgium: Submitting CARF–DAC8 XML files‍
• Dutch Tax and Customs Administration: DAC8/CARF for crypto-asset service providers‍
• Dutch Tax Administration digital reporting support: CARF/DAC8‍
• OECD: Crypto-Asset Reporting Framework (CARF)

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