DAC8 Crypto Reporting Guide (2026): Why WaaS Beats Manual Compliance

Executive Summary

• DAC8 introduces EU-wide DAC8 crypto reporting requirements that apply from 1 January 2026.
• The directive shifts crypto tax transparency from ad hoc reporting to systematic, recurring data production.
• Manual or spreadsheet-based reporting models do not scale to DAC8’s data, retention, and due-diligence requirements.
• Compliance feasibility increasingly depends on wallet and transaction infrastructure, not just policy interpretation.
• Wallet-as-a-Service (WaaS) aligns more naturally with DAC8’s operational demands by centralizing identity, transactions, and audit trails.
• Automation reduces operational risk, but does not remove the need for regulatory judgment or local interpretation.

What DAC8 Is and Why Crypto Platforms Can’t Ignore It

DAC8 is the EU’s extension of administrative cooperation rules into crypto-asset reporting. Its purpose is to give tax authorities consistent visibility into crypto transactions and user identities, similar to how financial account reporting already works in traditional finance.

Under DAC8, obligations apply to Reporting Crypto-Asset Service Providers (RCASPs)—entities that, as a business, facilitate the exchange, transfer, or custody of crypto-assets for users connected to the EU. The scope is defined by services performed, not by whether assets are held on-balance sheet.

From a timeline perspective, DAC8 rules apply from 1 January 2026, with reporting covering activity from that year onward. For exchanges and platforms, this means that systems operating today will soon be expected to produce DAC8-relevant data retrospectively and consistently.

What “DAC8 Reporting” Actually Requires Operationally

DAC8 is often discussed as a reporting obligation, but in practice it is a data lifecycle requirement.

Identity and attribution

Platforms must be able to associate reportable transactions with verified users, including identity and tax-relevant attributes. This is not a one-time KYC event; it is an ongoing requirement that must remain valid as accounts, wallets, and permissions evolve.

Transaction-level visibility

DAC8 crypto reporting requirements depend on complete, ordered records of:

• Deposits
• Withdrawals
• Transfers executed on behalf of users

These records must be attributable, internally consistent, and retained for multiple years.

Due diligence enforcement

DAC8 introduces explicit enforcement mechanics. If required user information is not provided after reminders and a minimum waiting period, the provider must restrict the user from performing reportable transactions. This turns compliance into an active operational control, not a back-office task.

Retention and auditability

Records must be stored for a defined multi-year period. Just as importantly, platforms must be able to explain how data was generated, approved, and modified if reviewed later.

Why Manual DAC8 Reporting Becomes Unrealistic at Exchange Scale

Many crypto platforms grew with reporting models that assume:

• Data can be pulled from multiple systems at year-end
• Gaps can be resolved manually
• Exceptions are rare

DAC8 breaks these assumptions.

Fragmented data sources

Wallet infrastructure, exchange ledgers, KYC systems, and approval tools are often separate. Reconciling them reliably for annual DAC8 crypto reporting introduces operational risk and repeated manual effort.

Attribution gaps

Modern exchange architectures involve sub-accounts, internal transfers, sweeping, and automated address generation. Without infrastructure that preserves attribution across these flows, reporting completeness becomes fragile.

Change amplification

New assets, new chains, or new product features can change reporting data structures mid-year. Manual pipelines struggle to absorb these changes without rework.

Remediation cost

When users fail due diligence requirements, platforms must act operationally. Doing this manually at scale increases both compliance risk and customer friction.

What “Automation-Ready” Architecture Looks Like for DAC8

DAC8 readiness is less about a single report and more about designing systems that can produce compliant data continuously.

Key architectural characteristics include:

• Consistent user identifiers across wallets, transactions, and approvals
• Event-level transaction logs that reflect the full lifecycle of funds
• Built-in controls that create an auditable trail of decisions
• A reporting pipeline that normalizes, validates, exports, and retains data without ad hoc intervention

As explained in our wallet-as-a-Service overview, these characteristics are difficult to retrofit onto fragmented wallet stacks.

Why Wallet-as-a-Service Fits the DAC8 Operating Model

Wallet-as-a-Service centralizes wallet operations behind a consistent API and governance layer. From a DAC8 perspective, this consolidation matters.

A WaaS approach can act as a single source of truth for:

• Deposit address creation and verification
• Asset collection and internal movement visibility
• Withdrawal execution and approval history
• Linkage between wallets and verified user identities

For example, platforms like CoinsDo expose wallet events, approval flows, and identity checks through modular services. CoinGet handles deposit address lifecycle and sweeping visibility, CoinSend and CoinSign log withdrawal execution and approvals, and CoinFace links wallets to verified users.

Used correctly, this does not make a platform “DAC8 compliant” by default. It does, however, reduce the number of systems involved in producing DAC8 crypto reporting data, which lowers reconciliation risk and manual effort.

FAQ

Is DAC8 the same as CARF?

No. DAC8 is the EU’s implementation aligned with global crypto reporting standards, but legal obligations are defined at the EU level.

Does non-custodial architecture avoid DAC8 obligations?

Not necessarily. DAC8 focuses on services provided, not just custody models.

What if we serve EU users but are not based in the EU?

DAC8 can still apply depending on how services are offered and who the users are. This requires legal analysis.

Where do platforms most often underestimate effort?

Data attribution across wallets and internal transfers.

Where does WaaS help most?

In reducing system fragmentation and producing consistent, auditable transaction data.