DAC8: What does the new EU regulation mean for Bitcoin users, merchants and wallets?
With DAC8, the EU is introducing a new reporting obligation for crypto companies. Many Bitcoiners are wondering:
What data is recorded? Who has to report? When does reporting start? And does this affect me at all if I hold Bitcoin long-term or store it myself?
In this article, we explain DAC8 as simply and practically as possible – and show you how to continue using Bitcoin in a confident and self-determined manner.
Note: We are not tax advisors and this article does not constitute tax advice.
The information is intended solely for general guidance on dealing with Bitcoin, Lightning and DAC8.
Tax regulations may differ from country to country and always depend on the individual situation of each user.
If in doubt, please seek advice from a qualified tax advisor on your personal tax situation.
What is DAC8?
DAC8 is the eighth extension of the EU Directive on Administrative Cooperation.
It obliges certain crypto service providers in the EU to report transactions and customer information to the national financial authorities.
The aim is an automatic exchange of data between the EU financial authorities to combat tax and money laundering.
Important:
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DAC8 only affects companies, not users.
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Only companies in the EU that have a MiCAR license (or require one) are required to register.
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Companies outside the EU (Switzerland, USA, Serbia, etc.) are not bound by DAC8.
When does DAC8 apply?
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Data collection: expected from 2026
(depending on the implementation date of the EU member states) -
Transmission to tax offices: from 2027
So there is still time to prepare – but the rules are definitely coming.
Which companies have to report?
DAC8 only applies to companies that:
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are resident in the EU
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are regulated under MiCAR (crypto exchanges, brokers, custody wallet providers)
Not affected are:
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Swiss provider
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Suppliers from the USA, UK, Serbia, Dubai, Australia, etc.
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Self-custody wallets without custody (as no company has access to the Bitcoin)
What is reported?
EU-regulated providers must report to the tax office:
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Identity of the customer
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Buying and selling Bitcoin & other assets
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Deposits and withdrawals
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Holdings in custody at the end of the year
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Movements between customer accounts
It does not matter whether the transactions are tax-relevant.
Even completely harmless purchases are recorded.
Example from practice
Example 1: Buying and selling on an EU stock exchange
You buy Bitcoin from an EU exchange or broker with a MiCAR license.
➡️ This data is sent to the tax office, regardless of this:
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whether you hold your Bitcoin for longer than 12 months
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whether your profit would be tax-free
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whether you are liable to pay tax at all
Many users consider this to be intrusive – because the state receives data that is often not tax-related.
Do you have to declare Bitcoin as an asset in Germany?
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No. There is no obligation to report Bitcoin assets annually.
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Gains are only taxable if they are sold within one year.
However, DAC8 means that purchases, sales and custody holdings of regulated EU providers are still automatically transmitted in the background.
Example 2: Purchase from a provider in Switzerland
A Swiss broker recently explained:
DAC8 does not apply to Swiss companies.
However, Switzerland is planning CARF – the international version of this.
CARF will come into force in 2027 at the earliest and will not apply retroactively.
Until then, no transactions will be reported to foreign authorities, except in the case of AML obligations.
➡️ Purchase in Switzerland = no DAC8 notification
➡️ CARF could bring local reporting obligations in 2027 at the earliest, but not for past years.
DAC8 and Bitcoin wallets
DAC8 only affects custody providers that store Bitcoin for customers.
Self-custody wallets: No DAC8 message
If you store your Bitcoin yourself, e.g. with:
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Hardware wallet (e.g. BitBox02, Trezor, Ledger)
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Self-custody lightning wallets (e.g. Phoenix, Breez)
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Wallet of Satoshi – self-custody variant (based in Australia)
➡️ No reporting to tax offices
➡️ No regulation by MiCAR or DAC8
Because: There is no custodian. No company can report.
Custody wallets from the EU: DAC8 notification
If a wallet is located in the EU and offers custody (keys are held by the provider):
➡️ Every deposit and withdrawal is reported.
DAC8 for Bitcoin payments
Payment by a user
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Self-custody wallet → Payment:
✔️ No DAC8 message -
EU-Custody Wallet → Payment:
❌ Is reported, as the provider must register the outflow.
Payment to a merchant
Case 1: Merchant receives Bitcoin directly on their own wallet
✔️ No DAC8 message
Payment is a peer-to-peer transfer.
Case 2: Merchant uses payment provider that stores or exchanges Bitcoin
❌ DAC8 message possible
If the payment provider:
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is based in the EU
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has a MiCAR license
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Bitcoin caches or pays out in euros
Customer data and transaction values must then be reported.
Recommendation for dealers
Merchants should use payment providers that pay out directly to their own wallet, e.g:
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BTCPay Server (Self-Hosted)
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Coinsnap, Flash, Zaprite (credit to the merchant’s self-custody wallet)
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Providers outside the EU
➡️ No safekeeping
➡️ No MiCAR obligation
➡️ No DAC8 data transmission
Conclusion
Of course, we assume that readers pay taxes honestly, in accordance with the laws of their country.
However, it is critical that DAC8 records all transactions as a precautionary measure – even if they are irrelevant for tax purposes.
Hence our basic recommendation – regardless of taxes:
1. always store Bitcoin yourself.
Hardware Wallet or Self-Custody Lightning Wallet.
2. buy and accept Bitcoin from service providers that pay out directly to your own wallet.
No custody = less risk, but DAC8 reporting still applies if the provider is EU-regulated. If you want to avoid DAC8 notifications, you should use service providers that are not based in the EU, as only EU MiCAR providers are subject to notification.
