Quarterly DAC8 Preparation Plan

Preparing for DAC8 compliance is not something that can be accomplished in a single sprint. It requires sustained, structured effort across multiple quarters. This article breaks down the preparation journey into a practical quarterly plan, from Q1 2026 through Q2 2027, giving your team a clear set of priorities for each period.

Q1 2026 (January - March): Foundations and Data Collection Launch

The first reportable period begins on January 1, 2026. By the start of this quarter, your core systems and processes should already be in place.

Priority tasks:

• Activate data collection workflows. Ensure that all new customer onboarding processes capture the information required under DAC8, including full legal name, date of birth, address, jurisdiction of residence, and Taxpayer Identification Number (TIN).
• Launch self-certification procedures. New customers should be completing self-certification forms as part of account opening. Validate that these forms meet the requirements set out in the directive and any applicable national legislation.
• Begin pre-existing account remediation. Identify all accounts that were open before January 1, 2026 and begin the process of gathering missing DAC8-required data from those customers.
• Confirm national transposition details. Review the transposition legislation in every member state where you have reporting obligations. Note any local variations in reporting format, deadlines, or additional requirements.
• Assign internal ownership. Ensure there is a named individual or team responsible for DAC8 compliance, with clear authority and adequate resources.

Q2 2026 (April - June): Process Refinement and Gap Analysis

With three months of data collection behind you, this quarter is about identifying and fixing gaps.

Priority tasks:

• Review data quality. Audit the data collected in Q1. How many customers have provided complete self-certifications? What is the TIN collection rate? Where are the gaps?
• Address collection shortfalls. For customers who have not provided required information, initiate follow-up procedures. Document your efforts to obtain missing data, as this may be relevant for demonstrating compliance.
• Test reporting logic. Begin building or configuring your reporting engine. Even though the first report is not due until 2027, testing against available schema specifications early will surface issues while there is still time to fix them.
• Engage with national authorities. If reporting portals or submission guidelines have been published, review them. If not, monitor official channels for updates.
• Train staff. Ensure customer-facing teams understand the DAC8 requirements and can explain self-certification procedures to customers.

Q3 2026 (July - September): Mid-Year Checkpoint

This is the halfway point of the first reportable period. Use this quarter to take stock and course-correct.

Priority tasks:

• Conduct a mid-year compliance review. Assess your overall readiness. Are data collection processes working as intended? Are there systemic issues that need to be resolved?
• Advance pre-existing account remediation. By now, you should have made meaningful progress on gathering data from pre-existing account holders. Escalate cases where customers have not responded to outreach.
• Refine transaction categorisation. Review how transactions are being classified for reporting purposes. Ensure that all reportable transaction types (transfers, exchanges, payments) are being captured correctly.
• Update policies and procedures. Based on lessons learned in the first two quarters, update internal policies, process documentation, and staff training materials.
• Monitor regulatory developments. Check for any updated guidance, FAQ documents, or clarifications from national authorities or the European Commission.

Q4 2026 (October - December): Year-End Preparation

The first reportable period closes on December 31, 2026. This quarter is about ensuring a clean close and preparing for reporting.

Priority tasks:

• Finalise data collection for 2026. Make a final push to resolve any outstanding data gaps. Document any cases where customer information could not be obtained despite reasonable efforts.
• Prepare for report generation. Ensure your reporting system can produce complete, accurate reports covering the full January 1 - December 31, 2026 period.
• Run end-to-end testing. Generate a draft report and validate it against the applicable schema. Check for completeness, accuracy, and formatting compliance.
• Document your compliance process. Compile records of your due diligence procedures, data collection efforts, and any decisions made regarding ambiguous cases. This documentation supports your compliance position.
• Plan the submission timeline. Map out the steps required to finalise and submit your report in Q1/Q2 2027, including internal review, approval workflows, and submission logistics.

Q1 2027 (January - March): Report Finalisation

With the reporting period closed, this quarter focuses on producing and validating the final report.

Priority tasks:

• Generate the final DAC8 report. Produce the report covering the full 2026 calendar year.
• Conduct quality assurance. Perform detailed validation checks. Cross-reference reported data against source records. Identify and correct any discrepancies.
• Obtain internal sign-off. Route the report through your internal approval process. Ensure that senior management or the responsible compliance officer has reviewed and approved the submission.
• Prepare for submission. Familiarise yourself with the submission process for each relevant national authority. Complete any registration or access requirements for reporting portals.

Q2 2027 (April - June): Submission and Exchange

This is the quarter when first reports are expected to be due and the first automatic exchanges are anticipated to begin.

Priority tasks:

• Submit reports to national authorities. File your DAC8 reports within the deadline established by each relevant member state.
• Retain submission confirmation. Keep records of when and how reports were submitted, including any confirmation receipts.
• Prepare for potential queries. National authorities may have questions or request corrections after reviewing submitted reports. Have your supporting documentation readily accessible.
• Begin planning for the next cycle. The 2027 reporting period is already underway. Apply lessons learned from the first cycle to improve processes for year two.

Following this quarterly structure transforms DAC8 preparation from an overwhelming project into a series of manageable, trackable milestones.