DAC8 Is in Force — and CARF Makes It Global

As of 1 January 2026, DAC8 formally entered into force across the European Union. This marks a decisive shift in how crypto-assets are treated for tax transparency purposes within the EU.

But DAC8 should not be viewed in isolation.

In reality, DAC8 is the EU implementation layer of a much broader international framework: the OECD Crypto-Asset Reporting Framework (CARF). And CARF is no longer hypothetical — it now has a concrete global rollout timeline.

Taken together, DAC8 and CARF mean that crypto tax reporting is moving from regional regulation to global automatic exchange of information.

DAC8: the EU Layer

DAC8 amends the Directive on Administrative Cooperation to introduce automatic exchange of information on crypto-assets between EU Member States.

It does not create new taxes.
It creates structured visibility.

Under DAC8, Reportable Crypto-Asset Service Providers (RCASPs) must collect, verify and report:

• taxpayer identification and tax residence,
• crypto-to-fiat transactions,
• crypto-to-crypto exchanges,
• crypto payments,
• and transfers between hosted platforms and self-custody wallets.

Reported data is exchanged automatically between EU tax authorities.

This moves crypto firmly into the same enforcement architecture that already exists for bank accounts, securities, and investment income.

Entry into Force vs. Implementation Reality

Formally:

• DAC8 had to be transposed by 31 December 2025
• It entered into force on 1 January 2026

Practically (as highlighted in recent IBFD analysis):

• implementation across Member States is uneven,
• several jurisdictions are still finalising legislation,
• and key operational elements (IT systems, portals, reporting guidance) are still being built.

This does not delay DAC8 — but it does mean that 2026 is a transition year in practice, especially for cross-border operators.

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CARF: the Global Backbone Behind DAC8

DAC8 is explicitly based on the OECD’s Crypto-Asset Reporting Framework (CARF).

CARF is designed to ensure that crypto-asset reporting works globally, not just within the EU. And as of November 2025, the OECD Global Forum published a clear commitment schedule.

First exchanges by 2027 (47 jurisdictions)

This group includes:

• most EU Member States (including the Netherlands, Germany, France, Italy, Spain, the Nordics),
• the UK,
• Japan,
• and a range of major financial centres.

For EU-based businesses, this means DAC8 data will start flowing internationally almost immediately.

First exchanges by 2028 (27 jurisdictions)

Including:

• Hong Kong,
• Singapore,
• Switzerland,
• UAE,
• Canada,
• BVI, Bermuda and other offshore centres.

This closes many of the classic “non-EU” assumptions around reporting gaps.

First exchanges by 2029

• United States.

The US is late — but not outside the system.

Jurisdictions not yet committed

Only a small number of countries (e.g. Argentina, India, Vietnam) are still uncommitted as of the last update.

The direction is unmistakable.

Why This Matters: DAC8 Is Not Just “EU Crypto Reporting”

A common mistake we still see is treating DAC8 as a purely European compliance issue.

It is not.

DAC8 is the EU’s CARF implementation, meaning:

• EU platforms will report under DAC8,
• that data will be exchanged under EU rules,
• and then increasingly matched globally under CARF.

In other words:
what starts as EU reporting does not stay in the EU.

Tax Residence Is the Real Risk Vector

Both DAC8 and CARF rely on tax residence, not citizenship or incorporation.

If tax residence data is:

• wrong,
• outdated,
• or inconsistently applied,

the same crypto activity can be:

• reported to the wrong jurisdiction, or
• reported to multiple jurisdictions.

For founders, executives, and investors with international mobility, residence analysis is now a first-order compliance issue.

Self-Custody and DeFi: Still Nuanced, Not Invisible

Self-custody remains legal.

However:

• transfers between regulated platforms and private wallets are reportable,
• and platform-level visibility does not disappear once assets move on-chain.

For DeFi, the familiar question applies:

is there a reportable intermediary or service provider?

Where there is governance, facilitation or control, reporting obligations may arise — mirroring the same fault lines already visible under MiCA.

Enforcement Is Built Into the Design

Both DAC8 and CARF are embedded in:

• audit cooperation,
• recovery assistance,
• and enforcement mechanisms.

Crypto is no longer structurally outside the tax enforcement perimeter.

The narrative of “technical unreachability” no longer aligns with regulatory reality.

What This Means in Practice (2026–2029)

From an O2K.tech perspective, this means:

• CASPs must prepare for EU and global reporting simultaneously
• Data consistency across platforms, wallets and filings becomes critical
• Historic activity will increasingly be contextualised retroactively
• Jurisdictional arbitrage based on reporting gaps is rapidly disappearing

DAC8 is the EU starting point.
CARF is the global end state.

Final Observation

MiCA decides who may operate in crypto markets.
DAC8 decides what EU tax authorities know.
CARF decides who else will know — worldwide.

Together, they mark crypto’s final integration into the global tax transparency framework.

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