First DAC8 Reporting Period: What to Expect

The first DAC8 reporting period is a critical milestone for crypto-asset service providers and operators across the European Union. This article explains exactly what the first reporting period covers, what data must be collected, and when reports are expected to be submitted.

The First Reporting Period: January 1 - December 31, 2026

The first DAC8 reportable period runs from January 1, 2026 through December 31, 2026. During this full calendar year, reporting entities must collect all data required by the directive and by their national implementing legislation. Every reportable transaction and every piece of customer due diligence information gathered during this period will form the basis of the first DAC8 report.

This means that by January 1, 2026, your data collection systems and onboarding processes must be fully operational. There is no grace period built into the directive for the start of data collection.

What Must Be Collected

During the first reporting period, reporting entities are expected to gather two broad categories of information: customer identity data and transaction data.

Customer Identity Data

For each reportable user, you must collect:

• Full legal name of the individual or entity.
• Date of birth (for individuals).
• Address of the customer.
• Jurisdiction(s) of tax residence. Customers may be tax resident in more than one jurisdiction, and all must be identified.
• Taxpayer Identification Number (TIN) for each jurisdiction of tax residence. Where a TIN is unavailable, the reason should be documented and, where applicable, a functional equivalent obtained.
• Entity classification (for non-individual customers), including identification of the entity type and, where relevant, the controlling persons.

This information is typically gathered through a self-certification process, where the customer provides a declaration of their tax residence and TIN. Reporting entities must have procedures in place to assess the reasonableness of self-certifications and to detect any indicators that the information may be inaccurate.

Transaction and Balance Data

For each reportable user, you must record:

• Crypto-asset transactions, including exchanges of crypto-assets for fiat currency, exchanges of one crypto-asset for another, and transfers of crypto-assets.
• Transaction values, expressed in the relevant fiat currency, with the applicable exchange rate at the time of the transaction.
• Number of units transacted, where applicable.
• Aggregate balances or values at relevant points, depending on the specific requirements of the national implementing legislation.

The directive covers a broad range of crypto-assets. Reporting entities should carefully review the definitions in both the directive and their national transposition to confirm which assets and transaction types fall within scope.

Pre-Existing Accounts

Accounts that were open before January 1, 2026 are considered pre-existing accounts. For these accounts, reporting entities must undertake a remediation process to obtain the required customer identity data, including self-certifications and TINs, that may not have been collected at the time the account was originally opened.

The directive provides a framework for this remediation, and national legislation may specify additional requirements or timelines. It is important to begin this process as early as possible, as reaching out to existing customers and obtaining their cooperation takes time.

Transactions involving pre-existing account holders that occur during the 2026 reporting period are reportable, regardless of whether the customer remediation process has been completed. This creates an urgency around obtaining missing data.

When Reports Must Be Submitted

The first DAC8 reports, covering the January 1 - December 31, 2026 period, are expected to be due to national tax authorities in 2027. The exact filing deadline will be determined by each member state's implementing legislation. Entities should monitor national guidance for confirmed submission dates.

Following the submission of reports to national authorities, the first automatic exchange of information between EU member states is anticipated to take place by September 30, 2027. This is the date by which national competent authorities are expected to share the collected data with the relevant tax authorities in other jurisdictions.

What the First Report Looks Like

While the precise format will be determined by the reporting schemas published by national authorities (expected to follow a common EU XML standard), the first report will generally contain:

• Identification details of the reporting entity.
• For each reportable user: the identity data described above.
• For each reportable user: the aggregated transaction data for the reporting period, broken down by transaction type.
• Any nil reports required (if applicable in the relevant jurisdiction), where the entity had no reportable transactions.

Practical Recommendations for the First Period

1. Do not delay data collection. The reporting period starts on January 1, 2026, and every day of delayed collection is a day of incomplete data.
2. Prioritise self-certification completion. Without a valid self-certification, you may not be able to accurately determine a customer's tax residence, which undermines the entire report.
3. Track TIN collection rates. Low TIN collection rates are a red flag for regulators and will weaken the quality of your submission.
4. Build reporting capabilities early. Do not wait until the reporting period is over to begin building your report generation process. Test early and iterate.
5. Document everything. Record your procedures, decisions, and any challenges encountered. This documentation will be valuable if your compliance is questioned.
6. Engage legal and tax advisors. Where the directive or national legislation is ambiguous, seek professional guidance. The first reporting period will inevitably involve interpretive questions.

The first reporting period sets the precedent for all subsequent cycles. Investing in getting it right from the outset will pay dividends in reduced effort and lower risk in future years.