DAC8 and CARF: The New Crypto Reporting Duty

Two reporting frameworks, one built by the OECD and one by the EU, are doing to crypto what the Common Reporting Standard did to offshore bank accounts. The important thing about them is not the acronyms. It is that the tax authority receives a structured dataset about your crypto activity, and your return is now checked against it.

What each one is

CARF, the OECD's Crypto-Asset Reporting Framework, is the international standard. Crypto asset service providers collect identifying information about their users and report their transactions to their own tax authority, which then exchanges that information with the authority where the user is resident. It is deliberately modelled on the Common Reporting Standard, which is why it will feel familiar to anyone who watched offshore banking secrecy end.

DAC8 is the European Union's directive implementing equivalent obligations within EU law, so that member states apply the regime consistently and exchange the resulting data among themselves.

Together they close the gap that made crypto different: the authority no longer depends on you telling it what happened.

What gets reported

The design intent of both frameworks is identification plus activity. In practice that means the provider knows who you are, including tax residence and identifiers, and reports your transaction activity in a form that can be matched to a taxpayer.

The consequence worth internalising is coverage rather than detail. A provider inside the regime reports whether or not you filed, whether or not you owe anything, and whether or not you ever converted to euros. Reporting is not conditional on there being tax to pay.

Why this matters more in Germany than elsewhere

German crypto taxation depends on facts the authority cannot infer from a transaction feed alone. Whether a gain is tax free turns on the holding period being more than twelve months. Whether the 1,000 euro Freigrenze applies turns on your aggregate private disposal gains for the year, and because it is an exemption limit rather than an allowance, exceeding it makes the entire gain taxable.

So an authority holding your disposals but not your acquisition dates sees gross activity without the facts that make it tax free. The burden of demonstrating the holding period sits with you, and that is exactly what the March 2025 BMF letter anticipates when it expects wallet level documentation with timestamps for each reward.

Put plainly: reporting frameworks do not create tax that was not owed. They create a need to evidence why it was not owed.

What actually changes for you

• Nothing about the rules. Section 23 private disposals, the one-year rule, FIFO, the Freigrenze, and section 22 income all work as before.
• Everything about evidence. A position you cannot document is now a position that visibly diverges from a dataset the Finanzamt holds.
• Self custody and non participating venues stand out more, not less. As the reported share of activity grows, unreported flows become more conspicuous rather than less, which is the opposite of what people assume.

What to do

1. Enumerate every exchange, broker and wallet you have used, including closed accounts. Providers report on periods, not on whether you still use them.
2. Export full history now, while accounts remain accessible.
3. Establish acquisition dates per lot, since the holding period is what makes German gains tax free and it is the fact least visible to a reporting provider.
4. Keep wallet level records with per reward timestamps for staking and lending, in line with what the BMF expects.
5. Check that your declared position can be reconciled to what a provider would plausibly have reported.

Our German crypto tax guide covers the rules the reported data will be measured against.

General information, not tax advice. Rules change and depend on your circumstances. Confirm the current position with the relevant tax authority or a qualified tax professional.