DAC8 Reporting in Germany: Practical Guide

The European Union's Directive on Administrative Cooperation (DAC8) extends automatic exchange of information to crypto-asset transactions. Germany, as one of Europe's largest economies with a significant crypto-asset market, is expected to implement robust reporting mechanisms. This guide covers the practical aspects of DAC8 reporting for crypto-asset service providers operating in Germany.

National Authority

The Bundeszentralamt fuer Steuern (BZSt), Germany's Federal Central Tax Office, is the competent authority responsible for receiving and processing DAC8 reports. The BZSt already handles various international tax information exchange obligations, including CRS and FATCA reporting, and is expected to oversee DAC8 compliance as well. Reporting entities should monitor official communications from the BZSt for updates on DAC8 implementation.

Submission Requirements

DAC8 reports in Germany are expected to be submitted electronically through the BZSt's existing digital infrastructure. Germany has a well-established electronic tax reporting ecosystem, and DAC8 submissions may be integrated into the BZSt Online Portal (BOP) or a dedicated channel for crypto-asset reporting.

• Format: Reports should follow the OECD Crypto-Asset Reporting Framework (CARF) XML schema, as specified in the DAC8 directive. Germany may issue additional technical guidance on formatting requirements.
• Language: Submissions are typically expected in German, though certain data fields may follow standardised international formats. The BZSt may provide specific guidance on language requirements for DAC8 filings.
• Authentication: Reporting entities will likely need to register with the BZSt and obtain appropriate electronic certificates for secure data transmission.
• Portal details: The exact submission portal or API endpoint for DAC8 reports is to be confirmed by the BZSt as the transposition process progresses.

Transposition Status

EU Member States are required to transpose the DAC8 directive into national law by December 31, 2025. Germany's Federal Ministry of Finance (Bundesministerium der Finanzen) is responsible for drafting the implementing legislation. As of the knowledge cutoff for this guide, the legislative process should be monitored for updates. Germany has historically met EU transposition deadlines for tax directives, though delays are always possible.

Local Variations

Germany may introduce specific requirements beyond the minimum DAC8 standards:

• Broader scope: German tax authorities have shown interest in comprehensive crypto-asset oversight and may extend reporting obligations to cover additional transaction types or lower thresholds.
• Integration with existing rules: Germany already taxes crypto-asset gains under Section 23 of the Income Tax Act (EStG). DAC8 reporting may be coordinated with existing domestic tax obligations.
• Registration requirements: Crypto-asset service providers operating in Germany typically need BaFin (Federal Financial Supervisory Authority) authorisation under MiCA. DAC8 reporting obligations may be linked to this regulatory framework.
• Due diligence: Germany may impose additional due diligence procedures on reporting entities to verify the identity and tax residency of crypto-asset users.

Key Dates

• Transposition deadline: December 31, 2025 (DAC8 must be incorporated into German law)
• Data collection begins: January 1, 2026 (reporting entities should begin collecting relevant data)
• First reporting period: Calendar year 2026
• First reports due: 2027 (the exact deadline is to be confirmed by the BZSt, but may align with existing CRS timelines, typically by June 30 or September 30)

Practical Tips

• Start preparation early: Given Germany's thorough regulatory approach, reporting entities should begin building their data collection and reporting systems well ahead of the 2026 start date.
• Monitor BZSt announcements: Subscribe to BZSt newsletters and monitor official publications for technical specifications and submission guidelines.
• Coordinate with BaFin obligations: Ensure that DAC8 reporting processes align with MiCA licensing and supervisory requirements administered by BaFin.
• Maintain thorough records: German tax authorities are known for detailed audits. Keep comprehensive documentation of all reporting processes, due diligence procedures, and submitted data.
• Seek professional advice: Given the complexity of German tax law, consider engaging a Steuerberater (tax advisor) with expertise in digital assets and international tax reporting.
• Test submissions: When the BZSt makes test environments available, use them to validate your reporting files before the official deadline.

Important Notice

This guide provides general information about DAC8 reporting in Germany. Requirements may change as the directive is transposed into national law. The information presented here reflects general expectations and should not be treated as definitive legal guidance. Always consult the Bundeszentralamt fuer Steuern (BZSt) and the Federal Ministry of Finance for the latest official requirements. For specific legal questions, seek advice from qualified German tax professionals.