DAC8 Implementation Milestones: Track Your Progress

Implementing DAC8 compliance is a multi-phase project with interdependent workstreams. Tracking progress against defined milestones ensures that nothing falls through the cracks and that dependencies are managed before they become blockers. This article provides a milestone-based framework from project kickoff through first submission, with guidance on critical path items and common dependencies.

Why Milestones Matter

DAC8 implementation involves legal analysis, technology changes, process design, customer outreach, and regulatory engagement. These workstreams run in parallel but depend on each other in specific ways. A milestone tracker provides visibility across all workstreams and highlights where delays in one area will cascade into others.

The Milestone Framework

The following milestones are presented in approximate chronological order. Actual timing will depend on your organisation's starting point, complexity, and the jurisdictions involved.

Phase 1: Project Initiation

Milestone 1.1: Establish Project Governance

• Appoint a project owner with clear accountability.
• Define the project team, including representatives from compliance, legal, technology, operations, and customer service.
• Secure budget and resource commitments.
• Dependency: Senior management sponsorship is required before resources can be allocated.

Milestone 1.2: Complete Regulatory Scoping

• Identify all EU member states where the entity has reporting obligations.
• Review the DAC8 directive and available national transposition legislation for each jurisdiction.
• Determine which products, services, and customer segments are in scope.
• Dependency: Scoping must be completed before detailed requirements can be defined.

Milestone 1.3: Conduct Gap Analysis

• Compare current data collection, storage, and reporting capabilities against DAC8 requirements.
• Identify gaps in customer data (particularly for pre-existing accounts), system capabilities, and operational processes.
• Produce a prioritised remediation plan.
• Dependency: The gap analysis depends on the completion of regulatory scoping (Milestone 1.2).

Phase 2: Design and Build

Milestone 2.1: Define Data Requirements

• Document the complete set of data elements required for DAC8 reporting, mapped to your internal systems and data sources.
• Define the data flow from collection through storage, processing, and report generation.
• Dependency: Requires completed gap analysis (Milestone 1.3) and confirmed reporting schema specifications.

Milestone 2.2: Design Self-Certification Process

• Design the self-certification form and workflow for new customers.
• Design the remediation outreach process for pre-existing customers.
• Ensure the process meets both DAC8 requirements and GDPR obligations (privacy notices, consent where applicable).
• Dependency: Data requirements (Milestone 2.1) must be finalised before the self-certification form can be designed.

Milestone 2.3: Build or Configure Reporting System

• Develop or procure the technology needed to generate DAC8 reports in the required format (expected to follow a common EU XML schema).
• Build data extraction, transformation, and validation logic.
• Dependency: Data requirements (Milestone 2.1) and reporting schema specifications must be available.

Milestone 2.4: Update Onboarding Processes

• Modify customer onboarding workflows to incorporate DAC8 data collection and self-certification from January 1, 2026.
• Update customer-facing interfaces, terms of service, and privacy notices.
• Dependency: Self-certification design (Milestone 2.2) must be finalised.

Phase 3: Testing and Validation

Milestone 3.1: Conduct Unit and Integration Testing

• Test individual system components (data collection, storage, extraction, report generation) in isolation and in combination.
• Validate that self-certification workflows function correctly end to end.
• Dependency: Build milestones (2.3 and 2.4) must be complete.

Milestone 3.2: Run End-to-End Report Generation Test

• Generate a complete test report using representative data.
• Validate the report against the applicable XML schema.
• Review the report content for completeness and accuracy.
• Dependency: Reporting system (Milestone 2.3) must be operational and test data must be available.

Milestone 3.3: Perform User Acceptance Testing

• Have compliance and operations staff review the processes and outputs.
• Confirm that the system meets business requirements and regulatory expectations.
• Document and resolve any defects or gaps identified.
• Dependency: Unit and integration testing (Milestone 3.1) should be substantially complete.

Phase 4: Go-Live and Data Collection (January 1, 2026)

Milestone 4.1: Activate New Account DAC8 Procedures

• From January 1, 2026, all new accounts must be onboarded with full DAC8 due diligence.
• Monitor that the new processes are functioning correctly in production.
• Critical path item: This date is fixed. All preceding design and build milestones must be completed before this date.

Milestone 4.2: Launch Pre-Existing Account Remediation

• Begin outreach to pre-existing account holders to collect missing data.
• Track response rates and manage follow-up communications.
• Dependency: Self-certification design (Milestone 2.2) and customer communication materials must be ready.

Milestone 4.3: Ongoing Data Quality Monitoring

• Establish regular monitoring of data collection metrics: TIN collection rates, self-certification completion, transaction recording accuracy.
• Address issues as they arise rather than waiting for year-end.
• Dependency: Data collection processes (Milestones 4.1 and 4.2) must be operational.

Phase 5: Report Preparation and Submission (2027)

Milestone 5.1: Close the Reporting Period

• After December 31, 2026, finalise the data for the first reporting period.
• Resolve any outstanding data quality issues.
• Dependency: Twelve months of data collection (Phase 4) must be complete.

Milestone 5.2: Generate and Validate the First Report

• Produce the final DAC8 report for the 2026 period.
• Run comprehensive quality assurance checks.
• Obtain internal approval from the designated compliance officer or senior management.
• Dependency: Reporting system (Milestone 2.3) must be proven through testing (Phase 3) and the reporting period must be closed (Milestone 5.1).

Milestone 5.3: Submit to National Authorities

• File the report with each relevant national tax authority within the applicable deadline.
• Retain confirmation of submission.
• Critical path item: The filing deadline is set by national legislation. All preceding milestones must be completed before this date.

Critical Path Summary

The critical path for DAC8 implementation runs through the following sequence:

1. Regulatory scoping and gap analysis
2. Data requirements definition
3. System build and self-certification design
4. Testing and validation
5. Go-live on January 1, 2026
6. Twelve months of data collection
7. Report generation and submission in 2027

Delays at any point in this sequence will compress the time available for subsequent steps. The most common risk areas are delays in finalising national transposition details (which affect data requirements and schema design) and low customer response rates during pre-existing account remediation.

Using This Tracker

Adapt this framework to your organisation's specific circumstances. Add dates, assign owners, and track status against each milestone. Review progress regularly, at least monthly, and escalate blockers promptly. The goal is not to have a perfect plan on paper, but to maintain clear visibility of where you are, where you need to be, and what stands in the way.