DAC8 Reporting in Estonia: Practical Guide

Estonia is widely recognised for its advanced digital governance infrastructure, including its pioneering e-Residency programme. The Maksu- ja Tolliamet (Estonian Tax and Customs Board) is expected to be the competent authority for DAC8 reporting. This guide covers practical aspects of DAC8 compliance for crypto-asset service providers (CASPs) operating in or serving users in Estonia, with particular attention to considerations related to e-residency.

Overview

DAC8 extends the EU's automatic exchange of information framework to crypto-assets. Estonia has historically been a popular jurisdiction for crypto-related businesses, partly due to its efficient digital licensing processes. CASPs registered in Estonia should prepare to collect user data and submit transaction reports to the Maksu- ja Tolliamet. Estonia's strong digital infrastructure may facilitate a relatively streamlined DAC8 implementation.

Competent Authority

The Maksu- ja Tolliamet (Estonian Tax and Customs Board) is the competent authority for tax administration, including the exchange of information under CRS and FATCA. It is expected to receive and process DAC8 reports. The Rahandusministeerium (Ministry of Finance) oversees tax policy and EU directive transposition.

Detail	Information
Authority name	Maksu- ja Tolliamet (Tax and Customs Board)
Parent ministry	Rahandusministeerium (Ministry of Finance)
Official gazette	Riigi Teataja
Tax ID format	Isikukood (personal ID, 11 digits) / Registry code (8 digits for entities)
Official language	Estonian

Key Requirements

CASPs should prepare to report the following under DAC8:

• Reportable users: Individuals and entities tax resident in EU member states who conduct reportable crypto-asset transactions.
• Transaction types: Crypto-to-fiat exchanges, crypto-to-crypto exchanges, and transfers of reportable crypto-assets are typically in scope.
• Data elements: Full name, address, date of birth, TIN (isikukood for Estonian individuals or registry code for entities), transaction gross amounts, and asset details.
• Due diligence: Self-certification and TIN validation procedures should be applied as specified under DAC8.
• E-Residency considerations: E-residents who operate CASPs through Estonian entities may have DAC8 reporting obligations in Estonia even if the beneficial owner resides elsewhere. The reporting obligation typically attaches to the entity, not the individual e-resident.

Submission Process

Estonia's digital-first approach to government services suggests that DAC8 submissions should be handled efficiently through electronic channels.

• Format: Reports should follow the OECD CARF XML schema. The Maksu- ja Tolliamet may publish supplementary technical guidance for Estonian submissions.
• Language: Official tax administration is conducted in Estonian. XML data fields should follow international conventions, but supporting documentation may need to be in Estonian.
• Submission channel: The Maksu- ja Tolliamet may integrate DAC8 reporting into its existing e-MTA electronic services portal, which is already used for CRS and other tax filings. The exact submission process is to be confirmed.
• Digital authentication: Estonia's eID and digital signature infrastructure may be used for authenticating DAC8 submissions. E-residents with Estonian digital ID cards should be able to access the filing systems.

Important Dates

• Transposition deadline: December 31, 2025 (directive must be incorporated into Estonian law)
• Data collection begins: January 1, 2026 (reporting entities should start collecting relevant data)
• First reporting period: Calendar year 2026
• First reports due: 2027 (exact date to be confirmed by Maksu- ja Tolliamet)

Practical Tips

• Register and access e-MTA: Ensure your entity has full access to the e-MTA electronic filing portal and the necessary digital certificates or eID credentials.
• Monitor the Riigi Teataja: All implementing legislation will be published in Estonia's Official Gazette (available online at riigiteataja.ee). Check regularly for relevant acts and regulations.
• Clarify e-Residency obligations: If your CASP operates through an Estonian e-Residency company, confirm with local advisors whether DAC8 reporting obligations apply in Estonia, in the country of the beneficial owner's residence, or both.
• Collect isikukood accurately: For Estonian-resident users, ensure your systems can capture and validate the 11-digit isikukood format.
• Leverage Estonia's digital ecosystem: Estonia's advanced digital identity and authentication infrastructure may simplify the submission process. Familiarise yourself with the available digital tools.
• Coordinate with Finantsinspektsioon: The Estonian Financial Supervision and Resolution Authority (Finantsinspektsioon) oversees financial services regulation and may handle MiCA licensing. Be aware of potential coordination between DAC8 and MiCA requirements.
• Engage local professionals: Consider engaging Estonian maksunoustajad (tax advisors) experienced in international reporting, digital assets, and e-Residency matters.

Important Notice

This guide provides general information about DAC8 reporting in Estonia. Requirements may change as the directive is transposed into national law. The information presented here should not be considered definitive legal or tax advice. Penalties for non-compliance vary by member state and are subject to national legislation. Always consult the Maksu- ja Tolliamet and the Ministry of Finance for the latest official requirements. For specific compliance questions, seek advice from qualified Estonian tax professionals.