DAC8 Self-Certification Template and Requirements

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

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Overview

Under DAC8 and the OECD CARF framework, Reporting Crypto-Asset Service Providers (RCASPs) must collect self-certification information from their users to determine tax residency. The self-certification is the foundation of the entire reporting process -- without it, you cannot correctly assign users to receiving jurisdictions or populate the required XML fields.

This article explains what a compliant self-certification must contain, provides a practical template, and covers the legal and operational requirements.

What Is a Self-Certification?

A self-certification is a formal declaration by a crypto-asset user stating their tax residency, tax identification number (TIN), and other identifying information. The RCASP relies on this declaration (combined with due diligence procedures) to determine where the user's data must be reported.

Self-certifications are not unique to DAC8 -- they are a standard mechanism in automatic exchange of information frameworks like CRS and FATCA. DAC8 extends this requirement to crypto-asset service providers.

Required Fields

A compliant self-certification must collect, at minimum, the following information:

For Individual Users

Field	Description	XML Mapping
Full legal name	First name, middle name (if applicable), last name	Individual/Name
Date of birth	In YYYY-MM-DD format	Individual/BirthInfo/BirthDate
Place of birth	City and country	Individual/BirthInfo/City, CountryCode
Current residential address	Full address including country	Individual/Address
Country(ies) of tax residence	One or more jurisdictions	Determines ReceivingCountry
TIN for each tax residence country	Tax identification number per jurisdiction	Individual/TIN
Nationality	Country of citizenship (if required by jurisdiction)	Individual/Nationality

For Entity Users

Field	Description	XML Mapping
Legal entity name	Registered name of the organisation	Entity/Name
Registered address	Official registered address	Entity/Address
Country(ies) of tax residence	Jurisdiction(s) of tax residence	Determines ReceivingCountry
TIN for each tax residence country	Business tax identification number	Entity/TIN
Entity type	Legal form (company, partnership, trust, etc.)	May be required by some jurisdictions
Controlling persons	Individuals who control the entity (if applicable)	May require separate self-certification

Sample Self-Certification Form

Below is a practical template that platforms can adapt. This is provided as guidance; your legal counsel should review the final form for compliance with applicable laws.

Section 1: Account Holder Identification

Full legal name:        ___________________________
Date of birth:          ____/____/________  (DD/MM/YYYY)
Place of birth (city):  ___________________________
Place of birth (country): ________________________
Nationality:            ___________________________

Current residential address:
  Street:               ___________________________
  City:                 ___________________________
  Postal/ZIP code:      ___________________________
  Country:              ___________________________

Section 2: Tax Residency Declaration

I declare that I am a tax resident of the following jurisdiction(s):

Country 1: _______________  TIN: ___________________
Country 2: _______________  TIN: ___________________
Country 3: _______________  TIN: ___________________

[ ] I confirm that the TIN(s) provided above are correct and currently valid.

If TIN is not available, please select a reason:
[ ] The jurisdiction does not issue TINs
[ ] I have applied for a TIN but have not yet received it
[ ] Other (please explain): ________________________________

Section 3: Declaration and Signature

I certify that:

1. I am the account holder (or authorised to sign for the account holder).

2. All information provided in this self-certification is true, correct,
   and complete to the best of my knowledge.

3. I undertake to notify [Platform Name] within 30 days of any change
   in circumstances that would affect the information provided herein,
   including any change in tax residency.

4. I understand that this information may be reported to the tax
   authorities of the jurisdiction(s) in which I am tax resident,
   under the EU Directive on Administrative Cooperation (DAC8) and/or
   the OECD Common Reporting and Due Diligence Standard for
   Crypto-Assets (CARF).

Signature: _________________________
Date:      _________________________

Digital vs. Paper Self-Certification

Digital (Electronic) Self-Certification

Most crypto-asset platforms will collect self-certifications digitally, either during onboarding or as a separate compliance step. Digital self-certification is permitted under DAC8, provided:

• The form captures all required fields
• The user explicitly confirms the declaration (e.g., checkbox or electronic signature)
• The platform stores the submission with a timestamp and an audit trail
• The declaration text is clearly presented and not hidden in terms of service

Implementation in practice:

<!-- Example: storing self-certification metadata in your system -->
<SelfCertification>
  <UserId>USR-00042</UserId>
  <SubmittedAt>2025-01-15T14:22:00Z</SubmittedAt>
  <Method>DIGITAL</Method>
  <IPAddress>192.168.1.100</IPAddress>
  <FormVersion>v2.1</FormVersion>
  <DeclarationAccepted>true</DeclarationAccepted>
</SelfCertification>

Paper Self-Certification

Paper forms may still be used but are less common for crypto platforms. If you accept paper self-certifications:

• Scan and store the signed document securely
• Enter the data into your system with a clear audit trail
• Retain the original document for the period required by applicable law

Timing Requirements

New Users

Self-certification should be collected at or before account opening. Many platforms integrate it into the KYC/onboarding flow. Under DAC8, a new user's self-certification must be obtained before the user can conduct reportable transactions, or within a reasonable timeframe defined by the implementing jurisdiction.

Existing Users (Pre-Existing Accounts)

For users who opened accounts before DAC8 comes into effect, RCASPs have a transitional period to collect self-certifications. The exact deadline depends on the implementation timeline, but platforms should plan to remediate their existing user base well in advance.

Changes in Circumstances

If a user notifies you of a change in tax residency or other relevant information, you must:

1. Obtain an updated self-certification
2. Adjust your reporting accordingly for the relevant period
3. Retain both the old and new self-certification for audit purposes

Reasonableness Test

RCASPs are not expected to independently verify every claim in a self-certification, but they must not accept information that is clearly unreasonable or contradicted by other data they hold. For example:

• If a user claims tax residency in France but their KYC address is in Germany, you should investigate the discrepancy
• If a user provides a TIN that is obviously invalid (e.g., wrong format for the claimed country), you should request correction

This is often called the "reasonableness test" and is a standard concept in CRS/FATCA due diligence that carries over to DAC8.

Data Retention

Self-certifications and supporting documentation must be retained for the period specified by applicable law -- typically at least five years after the end of the reporting period, though some jurisdictions require longer retention. Store self-certifications securely and ensure they are accessible for audit purposes.