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CARF / DAC8 readiness check

The first reporting period is calendar 2026 — it is running now, and the data is accruing whether or not anyone is collecting it. These are the questions worth answering honestly before the filing window opens, and what to do about each one you cannot.

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Scope and registration

Have you established, with an adviser, whether you are a Reporting Crypto-Asset Service Provider, and in which jurisdiction?

Everything else follows from this. Nexus can be tax residence, incorporation, management, a regular place of business, a branch, or — in the EU — MiCA authorisation or single registration.

Do you know your registration deadline, and have you registered where registration is separate from filing?

Several jurisdictions require registration well before the first return. The UK deadline for reporting crypto-asset service providers is 31 January 2027, months before the 31 May 2027 filing date.

Do you have a list of the Crypto-Asset Users you will have to report for the 2026 calendar year?

The first reporting period is calendar 2026. The population is fixed by what happened during that year, not by who is still a customer when you file.

Data you must hold

Do you hold a valid tax self-certification for each of those users — tax residence and TIN?

The self-certification is the due-diligence record behind every reported jurisdiction and TIN. Without it there is nothing to file and nothing to defend the filing with.

Have the TINs you hold been checked against the format of the jurisdiction that issued them?

A malformed TIN is a common rejection cause, and it is discovered at submission — after the deadline pressure has already started.

For entity users, have you identified the Controlling Persons that are Reportable Persons, with their control type?

A Passive NFE's Controlling Persons are reported alongside the entity, each coded CARF801–CARF813 by how they control it.

Do you hold the date of birth for every individual user, and place of birth where your domestic law requires it?

Date of birth is required for every individual. Place of birth is required only where your domestic law obliges you to obtain it and it is in your electronically searchable records.

Can your systems produce, per user and per crypto-asset, the annual aggregates for each of the eight reportable transaction categories?

CARF reports totals, not trades: acquisitions and disposals against fiat and against other crypto-assets, inbound and outbound transfers, transfers to unhosted wallets, and reportable retail payments above USD 50 000.

Do you have a documented method for valuing transfers where no market price applies at the time?

Where an alternative valuation is used it must be declared — book value, a third-party value, a recent valuation of your own, or a reasonable estimate.

Process and evidence

Is there a timestamped record of every self-certification request, reminder and account restriction?

When a tax authority asks why an uncertified account was still trading, the answer has to be a dated list of what was sent and when.

Filing and corrections

Do you have a way to correct or delete a record after filing, referencing what was originally sent?

A correction points at the DocRefID of the record it replaces, and must reference the latest version sent. That means keeping a durable ledger of every identifier you have ever issued.

Have you produced a test file in the OECD CARF XML format and validated it end to end?

The first time a return is generated is the wrong time to discover that the export puts elements in the wrong order or repeats a DocRefID.

Unanswered questions count as gaps. You can go back and change anything.

Reporting under a different regime? Run the DAC7 checklist