DAC8 Reporting Checklist: Complete Pre-Submission Guide

A thorough pre-submission checklist can help you avoid rejected reports, late filings, and costly rework. This guide provides a comprehensive, phase-by-phase checklist covering data collection through final submission. Use it as a template and adapt it to your national requirements.

> Disclaimer: This checklist is based on the general DAC8 framework established by Council Directive (EU) 2023/2226. National implementations may add or modify requirements. Always verify with your national tax authority before relying on this checklist as your sole reference.

Phase 1: Registration and Setup (12 items)

Complete these items well before the reporting deadline, ideally during initial onboarding or when DAC8 obligations first apply.

• [ ] 1.1 Confirmed your entity qualifies as a Reporting Crypto-Asset Service Provider (RCASP)
• [ ] 1.2 Identified your primary reporting jurisdiction (the Member State where you are registered or authorized)
• [ ] 1.3 Registered with the competent national tax authority as an RCASP
• [ ] 1.4 Received your reporting entity identifier or registration confirmation
• [ ] 1.5 Obtained the official XML schema (XSD) from your tax authority or the European Commission
• [ ] 1.6 Reviewed any national implementation guidance published by your tax authority
• [ ] 1.7 Identified the designated submission channel (portal, SFTP, API, or other)
• [ ] 1.8 Obtained access credentials for the submission channel
• [ ] 1.9 Tested connectivity to the submission system (if a sandbox or test environment is available)
• [ ] 1.10 Assigned internal responsibility for DAC8 compliance to a named individual or team
• [ ] 1.11 Established a compliance calendar with key deadlines
• [ ] 1.12 Engaged legal counsel or tax advisors for jurisdiction-specific guidance

Phase 2: Data Collection Infrastructure (10 items)

These items ensure your platform captures the data needed for reporting before the reporting period begins.

• [ ] 2.1 Self-certification form implemented in the user onboarding flow
• [ ] 2.2 Self-certification form collects: full name, address, date of birth, jurisdiction(s) of tax residence, and TIN(s)
• [ ] 2.3 Place of birth field added (may be required for individuals in some implementations)
• [ ] 2.4 TIN collection integrated with validation checks (format validation at minimum)
• [ ] 2.5 Tax residency self-certification includes a declaration and signature or electronic equivalent
• [ ] 2.6 Existing users have been contacted to provide missing self-certification data (remediation process)
• [ ] 2.7 Remediation tracking in place to monitor completion rates for existing users
• [ ] 2.8 Data retention policies updated to reflect DAC8 record-keeping requirements
• [ ] 2.9 GDPR-compliant privacy notice updated to reference DAC8 data processing
• [ ] 2.10 Data quality monitoring in place to flag missing or invalid fields on an ongoing basis

Phase 3: Transaction Data Preparation (8 items)

These items ensure your transaction records are complete, correctly categorized, and ready for aggregation.

• [ ] 3.1 Transaction types mapped to DAC8 categories (crypto-to-fiat, crypto-to-crypto, transfers, retail payments as applicable)
• [ ] 3.2 Fair market value calculation methodology documented and consistently applied
• [ ] 3.3 Pricing sources for fair market value identified and validated (e.g., exchange rate APIs, volume-weighted averages)
• [ ] 3.4 Transaction fees recorded and correctly attributed
• [ ] 3.5 Aggregation logic implemented to sum transactions by user, by crypto-asset type, and by transaction category
• [ ] 3.6 Internal transfers distinguished from reportable exchange transactions
• [ ] 3.7 Edge cases documented and handling procedures defined (e.g., staking rewards, airdrops, NFTs if in scope)
• [ ] 3.8 Reconciliation completed between transaction database totals and aggregated report totals

Phase 4: User Data Validation (8 items)

Before generating the report, validate all user-level data that will be included.

• [ ] 4.1 All Reportable Users identified based on transaction activity and residency criteria
• [ ] 4.2 Name fields checked for completeness (first name, last name at minimum; middle name if required)
• [ ] 4.3 Address fields validated for completeness and format (street, city, postal code, country code)
• [ ] 4.4 TINs validated against known country-specific formats
• [ ] 4.5 Tax residency jurisdiction codes verified against ISO 3166-1 alpha-2 country code standard
• [ ] 4.6 Date of birth fields present and in the expected format (typically YYYY-MM-DD)
• [ ] 4.7 Entity users (if applicable) have legal entity name, registration country, and entity TIN
• [ ] 4.8 Users with multiple tax residencies have all jurisdictions and corresponding TINs recorded

Phase 5: XML Report Generation (7 items)

These items cover the technical generation of the XML file itself.

• [ ] 5.1 XML generated using the correct version of the official XSD schema
• [ ] 5.2 MessageSpec header populated with correct reporting period, message type (new, corrective, or void), and sender/receiver identifiers
• [ ] 5.3 File encoded in UTF-8 (or as specified by your national tax authority)
• [ ] 5.4 Each Reportable User represented in a separate reporting block with all required sub-elements
• [ ] 5.5 Financial amounts formatted correctly (decimal separator, currency code, number of decimal places)
• [ ] 5.6 Unique message reference ID assigned to the report
• [ ] 5.7 XML file size checked against any limits imposed by the submission channel

Phase 6: Validation and Quality Assurance (8 items)

Validate the generated report before submission to minimize the risk of rejection.

• [ ] 6.1 XML file is well-formed (parseable by an XML parser without errors)
• [ ] 6.2 XML file validates against the official XSD schema without errors
• [ ] 6.3 Business rule checks passed (no missing mandatory fields, no invalid enumerations)
• [ ] 6.4 TIN format validation passed for all included TINs
• [ ] 6.5 Financial totals in the report reconcile with internal accounting records
• [ ] 6.6 Spot-check performed on a sample of individual user records for accuracy
• [ ] 6.7 No duplicate user records within the same report
• [ ] 6.8 Report reviewed and approved by a second person (four-eyes principle recommended)

Phase 7: Submission (5 items)

The final steps to deliver your report to the tax authority.

• [ ] 7.1 Report submitted through the designated channel before the deadline
• [ ] 7.2 Submission confirmation or receipt saved (screenshot, email, or system-generated acknowledgement)
• [ ] 7.3 Acknowledgement reference number recorded in your compliance records
• [ ] 7.4 Submitted XML file archived with a timestamp and version identifier
• [ ] 7.5 Submission date and method documented in your internal compliance log

Phase 8: Post-Submission (5 items)

After submission, monitor for issues and prepare for the next cycle.

• [ ] 8.1 Monitored for acceptance or rejection notification from the tax authority
• [ ] 8.2 If rejected, root cause identified and corrective report prepared within the allowed timeframe
• [ ] 8.3 Any tax authority queries responded to promptly and documented
• [ ] 8.4 Lessons learned documented for process improvement
• [ ] 8.5 Timeline and task list prepared for the next reporting period

Summary Table

Phase	Items	Priority
Registration and Setup	12	High - complete early
Data Collection Infrastructure	10	High - before reporting period
Transaction Data Preparation	8	Medium - during reporting period
User Data Validation	8	High - before report generation
XML Report Generation	7	Medium - scheduled process
Validation and Quality Assurance	8	High - before submission
Submission	5	Critical - deadline-driven
Post-Submission	5	Medium - ongoing
Total	63

Using This Checklist

This checklist contains 63 items across 8 phases. Not every item may apply to every organization or jurisdiction. You should:

1. Review each item against your national tax authority's published guidance
2. Remove or modify items that do not apply to your specific situation
3. Add jurisdiction-specific items as needed
4. Assign owners and deadlines to each item
5. Track completion in your project management or compliance tool

Consider running through this checklist as a tabletop exercise before your first reporting deadline to identify gaps in your processes.

This checklist is for informational purposes only and does not constitute legal or tax advice. Requirements may differ based on your jurisdiction and the final national transposition of DAC8.