NFT Reporting Under DAC8: What Qualifies

Category: XML Templates Last Updated: 2026-02-12 Applies To: EU DAC8 / OECD CARF XML Schema

---

Overview

Non-fungible tokens (NFTs) present unique challenges for DAC8/CARF reporting. While the OECD CARF framework is designed primarily around fungible crypto-assets like Bitcoin and Ethereum, its broad definition of "Relevant Crypto-Asset" potentially captures certain NFTs. However, not all NFTs fall within scope, and the valuation and reporting mechanics differ significantly from fungible tokens.

This article examines which NFTs may be reportable under DAC8, the valuation challenges involved, and a practical approach to implementation.

Do NFTs Fall Under DAC8 Scope?

The answer is: it depends on the NFT and the jurisdiction's implementation.

The OECD CARF framework defines Relevant Crypto-Assets broadly as digital representations of value that use cryptographically secured distributed ledger technology and can be transferred or held electronically. This definition could encompass NFTs, since they are blockchain-based digital assets.

However, the framework also contains certain exclusions, and individual jurisdictions may further narrow or clarify the scope when transposing DAC8 into national law.

Likely In Scope

• NFTs used as a means of payment or investment. If an NFT is primarily held for speculative purposes or used in exchange transactions, it is more likely to be considered a Relevant Crypto-Asset.
• NFTs traded on RCASP platforms. If your platform facilitates the buying, selling, or exchanging of NFTs, those transactions may fall under reporting obligations.
• Fractionalized NFTs. NFTs that have been divided into fungible fractions (e.g., via fractional ownership protocols) behave more like fungible tokens and are more clearly within scope.

Potentially Excluded

• NFTs representing real-world assets with separate regulatory frameworks. For example, NFTs that represent securities may fall under different reporting regimes.
• NFTs used solely for non-financial purposes. Digital art used for personal enjoyment without trading may not constitute a "means of exchange or investment" under certain interpretations.
• Closed-ecosystem NFTs. Gaming items or loyalty tokens that cannot be traded on open markets may be excluded under some implementations.

> Caution: The scope of NFT reporting under DAC8 is an area where jurisdiction-specific guidance is essential. Do not assume NFTs are out of scope without checking local implementation rules. When in doubt, the conservative approach is to include them.

Valuation Challenges

NFTs are, by definition, non-fungible -- each one is unique. This creates significant valuation challenges compared to fungible crypto-assets where market prices are readily available.

Sale Price as Fair Market Value

When an NFT is sold (exchanged for fiat or another crypto-asset), the sale price is the most reliable indicator of value:

User sells NFT "CryptoArt #4521" for 2.5 ETH on 2025-09-15
ETH/EUR price at time of sale: 1,900.00 EUR

FMV of transaction = 2.5 * 1,900.00 = 4,750.00 EUR

This is the most straightforward scenario and follows the same logic as any crypto-to-crypto exchange.

Transfer Valuation

When an NFT is transferred to an external wallet (not sold), determining FMV is more difficult:

• If the NFT was recently purchased: Use the purchase price as an approximation
• If there is a floor price for the collection: Use the collection floor price with appropriate caveats
• If no reliable price exists: This is a genuine challenge. You may need to use the last known sale price, an appraisal, or a reasonable estimate

> Important: Document your valuation methodology for NFTs thoroughly. Tax authorities may scrutinise NFT valuations more closely due to the inherent subjectivity.

Asset Identification

Unlike fungible tokens (where AssetCode is simply BTC or ETH), NFTs require more specific identification. The schema may support:

<CryptoAssetDetails>
  <AssetCode>NFT</AssetCode>
  <AssetDescription>CryptoArt Collection #4521</AssetDescription>
  <ContractAddress>0x1234...abcd</ContractAddress>
  <TokenId>4521</TokenId>
</CryptoAssetDetails>

> Note: The exact fields available for NFT identification depend on the final schema version. The OECD CARF schema may use a generic AssetCode of NFT or a similar indicator, with additional descriptive fields. Verify against the published XSD.

If the schema does not provide NFT-specific fields, use the most descriptive approach available within the schema's constraints.

XML Encoding for NFT Transactions

NFT Sale (Crypto-to-Crypto Exchange)

<TransactionSummary>
  <TransactionType>EXCHANGE_CRYPTO</TransactionType>
  <NumberOfTransactions>1</NumberOfTransactions>
  <AggregateGrossProceeds currCode="EUR">4750.00</AggregateGrossProceeds>
  <CryptoAssetDetails>
    <AssetCode>NFT</AssetCode>
    <TotalUnits>1</TotalUnits>
  </CryptoAssetDetails>
</TransactionSummary>

NFT Sale for Fiat

<TransactionSummary>
  <TransactionType>EXCHANGE_FIAT</TransactionType>
  <NumberOfTransactions>1</NumberOfTransactions>
  <AggregateGrossProceeds currCode="EUR">3200.00</AggregateGrossProceeds>
  <CryptoAssetDetails>
    <AssetCode>NFT</AssetCode>
    <TotalUnits>1</TotalUnits>
  </CryptoAssetDetails>
</TransactionSummary>

NFT Transfer to External Wallet

<TransactionSummary>
  <TransactionType>TRANSFER</TransactionType>
  <NumberOfTransactions>2</NumberOfTransactions>
  <AggregateTransferValue currCode="EUR">8500.00</AggregateTransferValue>
  <CryptoAssetDetails>
    <AssetCode>NFT</AssetCode>
    <TotalUnits>2</TotalUnits>
  </CryptoAssetDetails>
</TransactionSummary>

Aggregation Considerations

NFTs present a unique aggregation challenge. Since each NFT is unique, aggregation by "asset code" is less meaningful than for fungible tokens. Consider:

• Collection-level aggregation: Group NFTs from the same collection (e.g., all Bored Ape Yacht Club NFTs traded by a user) into a single summary if the schema supports this
• Generic NFT aggregation: If the schema only supports a generic NFT asset code, all NFT transactions of the same type would be aggregated into a single summary
• Individual reporting: If each NFT must be reported separately (unlikely for aggregate reporting but possible), create separate TransactionSummary blocks per NFT

The practical approach depends on the schema's flexibility. For aggregate reporting, grouping all NFT transactions of the same type into a single summary with AssetCode of NFT is likely the simplest compliant approach.

Marketplace Platform Considerations

If you operate an NFT marketplace:

• Seller-side reporting: When a user sells an NFT on your platform, this is a reportable exchange transaction for the seller
• Buyer-side: The buyer acquires a crypto-asset. Depending on the framework, the purchase may not itself be a reportable event (similar to how buying BTC with fiat is not reported as an exchange from the buyer's perspective)
• Royalties: Secondary sale royalties paid in crypto to the original creator may constitute separate reportable events. Classify them according to the applicable transaction type
• Platform fees: Marketplace fees follow the same rules as exchange platform fees -- determine whether to report gross or net proceeds consistently

Practical Recommendations

1. Check jurisdiction guidance first. Before investing heavily in NFT reporting infrastructure, confirm whether your jurisdiction explicitly includes or excludes NFTs from DAC8 scope.

1. Start with clear cases. NFTs that are bought and sold on your platform for fiat or crypto have clear transaction values. Focus on these first.

1. Document everything. NFT valuation is inherently subjective. Maintain detailed records of how you determined FMV for each transaction, especially for transfers.

1. Plan for schema evolution. The OECD CARF schema may be updated to better accommodate NFTs. Build your reporting system with flexibility to adapt to new fields or classification requirements.

1. Monitor regulatory developments. NFT reporting under DAC8 is an evolving area. Stay current with OECD publications and your jurisdiction's implementing legislation.