DAC8: preparing data and keeping reliable records
Published 17/12/2025 · Updated 08/09/2026 · Houssen Issouf Aly, French chartered accountant
Crypto-assets · Companies · Directors
Practical guidance for companies and directors. Revised on 7 September 2026.
Original article: 2025-12-17 · HODL Consulting
Information exchange, not a new tax rate
DAC8 governs the collection and exchange of tax information about crypto-assets. Tax authorities receive records from reporting providers and exchange them under the applicable rules. It does not replace the taxpayer’s obligations or create a universal capital-gains calculation.
Reporting provider and user: different roles
A provider within scope needs to determine its obligations, perform the required due diligence, collect information and prepare a return. A user, whether an individual or company, may receive requests about identity, tax residence or status. Holding crypto-assets for its own account does not automatically make a company a reporting provider.
For a company, requests must identify the correct entity and, where required, its controlling persons. A brand, director and company are not interchangeable account holders. MiCA regulatory status and tax reporting obligations also have different scopes.
Transaction information is not necessarily a taxable gain
Data may include aggregate amounts and quantities by asset and transaction category. A total of sales, purchases or transfers is not automatically taxable profit. Company accounting and individual tax calculations still require appropriate reconciliation and classification.
Example: a transfer of 0.5 BTC between two accounts owned by the same company may appear as an outgoing movement at one provider and an incoming movement at another. The file should connect both movements and establish ownership. Reading each statement separately may otherwise misrepresent the activity.
The EU timetable
Distinguish the transaction period, the provider’s filing deadline and exchanges between tax authorities. They are not one deadline.
- From 1 January 2026: the first transaction period covered by the new rules.
- In France, before 15 June of the following year: article 19 of Decree 2025-1276 sets the reporting provider’s filing deadline. Under that text, 2026 data is filed before 15 June 2027.
- By 30 September 2027: the first exchanges between tax authorities concerning 2026, according to the European Commission.
Providers reporting in another country need to check domestic requirements. French formats and technical procedures are published on the DGFiP CARF/DAC8 page. Collection, controls and corrections need to be organised before filing.
Sources: Decree of 19 December 2025, particularly article 19 and European Commission — DAC8.
What a company can prepare
The practical task is to make records explainable. Keep complete exports independently of account access and verify the legal identity and tax residence recorded by each provider.
If your company uses platforms
- List accounts, holders, contracting entities and periods of use.
- Correct inaccurate information with appropriate supporting documents.
- Export purchases, disposals, swaps, fees and transfers, including from closed accounts.
- Reconcile wallet movements and explain timing or valuation differences.
- Retain requests, responses and associated evidence in a tracked file.
If you are a reporting provider
Build a process connecting customer data, transactions and the reporting file. Assign responsibility for collection, missing-data review, file approval and response handling. Controls should cover identifiers, duplicates, transaction categories, quantities and reported values.
Test complete sample cases before scaling up: account opening, residence changes, corrections and transfers. Technical acceptance of a file does not by itself prove that all data is accurate. Our support for crypto providers can help define the required accounting and coordination work.
Frequently asked questions
Does DAC8 replace my personal tax return? No. Provider and taxpayer obligations remain separate. The individual tax guide explains calculation records and annexes.
Is the reported amount necessarily my profit? No. Understand the data category and reconcile it with the applicable accounting or tax treatment.
Does a personal wallet remove all tax questions? Custody arrangements alone do not determine tax treatment. Keep histories and assess the relevant transactions.
Does a request for a tax identification number validate my situation? It is information collection, not confirmation of the tax calculation or correction of an earlier return.