Annual DAC8 Reporting Calendar

After the first DAC8 reporting cycle is complete, reporting entities enter an ongoing annual rhythm. While the initial effort of building systems and establishing processes is the heaviest lift, the annual cycle brings its own demands: data collection continues year-round, reports must be generated and submitted on schedule, and regulatory developments must be monitored. This article outlines what the ongoing annual reporting calendar looks like.

The Annual Cycle in Summary

Each DAC8 reporting year follows the calendar year, running from January 1 through December 31. The report for each calendar year is then prepared and submitted to the relevant national tax authorities during the following year, after which automatic exchanges between member states take place.

The annual cycle can be broken into four broad phases:

1. Continuous data collection (January - December of the reporting year)
2. Year-end close and data finalisation (December - January)
3. Report preparation and submission (early months of the following year)
4. Post-submission activities and next-cycle preparation (ongoing)

Month-by-Month Calendar

The following calendar provides a general framework for ongoing annual DAC8 reporting. Exact deadlines for report submission will depend on national legislation in each relevant jurisdiction.

January

• New reporting year begins. All transactions from January 1 onward fall into the new reporting period.
• Complete year-end data reconciliation for the prior reporting period.
• Begin generating the DAC8 report for the prior year.
• Process any new customer onboardings with full DAC8 due diligence.

February - March

• Finalise the DAC8 report for the prior year. Run validation checks against the applicable reporting schema.
• Conduct quality assurance: cross-reference reported figures against source transaction data.
• Obtain internal sign-off from the responsible compliance officer or senior management.
• Begin submission process if the national deadline falls in this period.

April - June

• Submit DAC8 reports to national tax authorities within applicable deadlines. (The first automatic exchanges are anticipated by September 30 each year, meaning national filing deadlines are expected to fall well before this date.)
• Retain submission confirmations and archive the submitted report.
• Address any queries or correction requests received from national authorities.
• Review data collection processes and make adjustments based on lessons learned from the prior cycle.

July - September

• Mid-year checkpoint: review data quality for the current reporting period. Check TIN collection rates, self-certification completion, and transaction recording accuracy.
• Automatic exchange of information between EU member states is anticipated to occur around September 30 each year. While this is handled by the national authorities rather than reporting entities directly, it is useful to be aware of this timing in case follow-up queries arise.
• Continue outreach to customers with incomplete or outdated self-certifications.

October - December

• Begin preparing for year-end close. Ensure all data collection processes are functioning correctly heading into the final quarter.
• Monitor regulatory developments: review any updates to national guidance, reporting schemas, or procedural requirements that may affect the next filing cycle.
• Conduct staff refresher training on DAC8 procedures.
• Plan the timeline for next year's report preparation and submission.

Recurring Annual Tasks

Beyond the monthly calendar, several tasks recur each year and should be built into your annual compliance plan.

Self-Certification Maintenance

Self-certifications are not a one-time exercise. Reporting entities must monitor for changes in circumstances that would affect a customer's tax residence status. Where a change is identified, an updated self-certification should be obtained. Additionally, some national implementations may require periodic re-certification for certain customer categories.

TIN Validation

TIN collection and validation should be an ongoing process. Where TINs were not obtained during the prior cycle, continued efforts must be made. Where national authorities provide TIN verification tools or feedback, use them to validate the accuracy of the TINs you hold.

Regulatory Monitoring

DAC8 is part of a broader and evolving regulatory landscape. Related developments, such as updates to the OECD Crypto-Asset Reporting Framework (CARF), changes to MiCA requirements, or amendments to the DAC directive itself, may affect your reporting obligations. Designate someone in your team to monitor regulatory developments on an ongoing basis.

System and Process Updates

Reporting schemas, submission portals, and validation rules may be updated by national authorities between reporting cycles. Ensure your systems are updated to reflect any changes before the next filing deadline.

Internal Audit and Review

Conduct an annual internal review of your DAC8 compliance processes. Assess whether procedures were followed, whether data quality met expectations, and whether any incidents or near-misses occurred. Use the findings to improve processes for the next cycle.

Managing Multi-Jurisdiction Reporting

Entities with reporting obligations in more than one EU member state face additional complexity in the ongoing calendar. Different jurisdictions may have different filing deadlines, different submission portals, and different data format requirements.

To manage this effectively:

• Maintain a master calendar with the filing deadline for each jurisdiction.
• Standardise your internal data collection and quality assurance processes, then apply jurisdiction-specific formatting and submission steps at the end.
• Build sufficient time into your schedule to handle the jurisdiction with the earliest deadline first, and to accommodate any jurisdiction-specific issues.

The Long-Term View

DAC8 reporting is a permanent obligation for in-scope entities operating in the EU. The effort required in each subsequent year should be less than the first cycle, provided that systems are well-designed and processes are documented and repeatable. However, complacency is a risk. Regulatory requirements evolve, customer bases change, and systems require maintenance.

Building DAC8 compliance into your regular operational calendar, rather than treating it as an annual project, is the most reliable way to maintain compliance over the long term.