The reporting obligation was expanded to include all EU‑resident users, including those resident in the Member State where the provider is established, and to require RCASPs to collect data on both resident and non‑resident investors.
Before
RCASPs only had to collect information on transactions of non‑resident investors and start gathering data on EU‑resident users (excluding domestic residents).
After
RCASPs must now collect information on transactions of both resident and non‑resident investors and start gathering data on all EU‑resident users, including domestic residents.
Source: EU DAC8 / CARF — Crypto Tax Reporting (live Jan 2026)
View original source →What this means for you
Centralized Exchange
Act nowWhy this matters
As a CEX that is responsible for reporting obligations and holds licenses (such as CASP), the company must now expand its data collection to include all EU-resident users, including those in its own home Member State. Failure to capture this expanded dataset for both resident and non-resident investors would result in a direct breach of reporting mandates.
What to do
Update user onboarding and transaction monitoring systems to collect and store the required data for all EU-resident users, regardless of their country of residence.
DeFi Protocol
Doesn't applyWhy this matters
The regulatory change applies specifically to RCASPs (Registered Crypto-Asset Service Providers), which are centralized entities. As a fully decentralized protocol with no operator, owner, or custody of assets, this profile does not meet the definition of a service provider capable of collecting or reporting user data.
Custodian
Review soonWhy this matters
As a custodian holding assets for EU-resident clients, the company must now expand its data collection and reporting mechanisms to include domestic residents and non-residents. Failure to capture this transaction data for all EU users would result in non-compliance with the expanded reporting obligations.
What to do
Update client onboarding and transaction monitoring systems to collect and store the required reporting data for all EU-resident and non-resident investors.