As global regulatory frameworks rapidly evolve, digital asset platforms are under increasing pressure to meet stringent tax transparency standards. The recent webinar, “Unlocking Compliance at Scale: CARF/DAC8 Reporting for Digital Asset Platforms,” featured an expert panel, including:
- Beatriz Castaneda – Director, Tax Information Reporting, Coinbase
- Jill Dymtrow – Director, Tax Information Reporting, Gemini
- Jamison Sites – Principal, Tax, Asset Management, KPMG
- Erin Fennimore – VP of Tax Solutions, Taxbit (Moderator)
The discussion focused on how organizations are preparing to meet the demands of the OECD’s Crypto-Asset Reporting Framework (CARF) and the EU’s DAC8 directive, and how these regimes are shaping the future of cross-border compliance in the digital asset space.
This recap summarizes the key insights, best practices, and practical considerations shared by the panel, with a focus on readiness, regulatory interpretation, reporting challenges, and the long-term operational impact of these rules.
Watch the webinar on demand today to learn more.
Global Readiness and the Compliance Timeline
One of the clearest messages from the webinar was that time is running short for compliance planning. While full reporting obligations under CARF and DAC8 may not begin until 2027, customer due diligence requirements begin on January 1, 2026. This includes collecting CARF self-certification forms, establishing onboarding procedures, and determining whether an entity qualifies as a Reporting Crypto-Asset Service Provider (RCASP).
Jamison Sites, Principal at KPMG and a digital asset tax specialist, emphasized the urgency:
“You can start on those processes while these other items are sorted out… If you don’t have the right data going in, you’re never going to have the right data going out.”
Many attendees admitted they were still early in their planning journey. A live poll revealed that 50% were just getting started, while 30% were evaluating options and only 20% had a concrete plan in place.
Beatriz Castaneda, Director of Tax Information Reporting at Coinbase, confirmed that even large global exchanges are still assessing scope:
“We were hoping that countries would be much further along in their legislation… Now we know we don’t have that luxury.”
The delay in national-level implementation adds complexity to compliance planning. Although countries like France, Sweden, Spain, and Norway have made progress, many others remain in draft stages or are just beginning.
Due Diligence and Self-Certifications: New Standards and New Challenges
The customer due diligence requirements under CARF and DAC8 are significantly more stringent than what many digital asset platforms are accustomed to. These include the collection of tax residency self-certifications, TINs, and in the case of entities, information on controlling persons.
While this aligns with familiar processes under CRS and FATCA, the expectations for enforcement and accuracy are higher under DAC8. For new accounts opened on or after January 1, 2026, CARF requires that self-certifications be collected at the start of the relationship, and DAC8 introduces a 60-day rule that requires service to be suspended if the certification is not obtained.
Jill Dymtrow, Director of Tax Information Reporting at Gemini, noted:
“CARF is more helpful in being specific about when to get information — at the beginning of the relationship… That’s a bit more clear than U.S. rules.”
However, the real challenge may lie with pre-existing accounts, which often lack complete documentation. As Castaneda pointed out:
“We expect this to be a pretty painful exercise for pre-existing users… Crypto users are not always familiar with the idea of providing tax documentation the way traditional investors are.”
Complicating matters further is the rising concern around phishing and fraud. Dymtrow emphasized the operational tension:
“There’s a massive level of phishing scams targeting digital asset investors… So documentation outreach has to be extremely thoughtful and secure.”
Reporting Complexity: Going Beyond Balances to Transaction-Level Aggregation
CARF introduces transaction-level reporting requirements that go far beyond what CRS demands. Instead of annual account balances, platforms must report aggregate transaction values per asset type and transaction category, including:
- Crypto-to-fiat
- Crypto-to-crypto
- Retail payments
- Transfers (in and out)
These transactions must be aggregated annually but also disaggregated by type and crypto asset, introducing a significant data management challenge.
“This is going to be a volume that eclipses even what we’ve seen for CESOP or CRS,” warned Castaneda.
Sites emphasized the importance of automation:
“No individual is going to be able to do this manually. Whether you build in-house or buy, there has to be a software solution.”
And the complexity doesn’t stop at data transformation. Panelists highlighted the challenges of adapting to local XML schemas, portal submissions, and registration requirements — all of which can vary drastically by jurisdiction. As Dymtrow recalled from her CRS experience:
“We had data specifications, but files would fail due to formatting quirks that weren’t documented. A comma instead of a period could reject the whole submission.”
U.S. Participation and the Regulatory Uncertainty Ahead
The U.S. has not yet decided whether to join CARF, despite it being a global framework. Historically, the U.S. prefers bilateral agreements (e.g., FATCA IGAs) over multilateral regimes. Key questions under discussion at a recent IRS/Treasury roundtable:
- Will the U.S. require beneficial-ownership reporting under CARF?
- How would CARF reporting interact with existing Section 6045 rules?
Adopting CARF would likely require changes to existing intergovernmental agreements (IGAs), since:
- Current U.S. IGAs may legally prevent sharing data with foreign governments without modification.
- The U.S. typically “goes its own route” rather than conforming to global data-exchange standards.
For U.S.-based digital-asset firms operating globally, this uncertainty affects:
- Data-collection strategies (e.g., deciding which ownership information to gather)
- Onboarding processes (since compliance requirements may shift)
- Resource planning (teams must remain flexible in case CARF adoption moves forward)
Final Thoughts
The CARF and DAC8 frameworks represent a turning point in the regulation of digital asset platforms. As jurisdictions move from conceptual frameworks to enforceable obligations, firms that begin their compliance journey early — especially around data readiness and customer onboarding — will be best positioned to adapt.
While technical hurdles and regulatory uncertainty remain, collaboration across tax, legal, operations, and product teams — paired with strong vendor partnerships — will be key to unlocking compliance at scale.
