RCASPs must now register in a Member State if not authorised under MiCA and begin collecting data on EU‑resident users from 1 January 2026.
Before
RCASPs only had to collect information on transactions of non‑resident investors and exchange it within 9 months after the reporting year.
After
RCASPs must complete a single registration in the Member State and start gathering data on reportable crypto‑asset transactions of EU‑resident users starting 1 January 2026.
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 custodies funds and manages user accounts, the company fits the profile of a CASP/RCASP. Failure to register in a Member State and implement data collection for EU residents by the deadline would result in an inability to legally serve the EU market.
What to do
Complete the registration process in a chosen EU Member State and update user onboarding and transaction monitoring systems to collect required data on EU-resident users.
Deadline: Jan 1, 2026
DeFi Protocol
Doesn't applyWhy this matters
The regulatory change applies specifically to RCASPs (Registered Crypto-Asset Service Providers), which are entities providing services. As a fully decentralized protocol with no identifiable operator or controlling party, there is no legal entity to register or perform data collection.
Deadline: Jan 1, 2026
Custodian
Review soonWhy this matters
As a custodian, the company qualifies as a Crypto-Asset Service Provider (CASP) under MiCA. If it serves EU-resident clients but is not yet MiCA-authorised, it must register in a Member State to maintain legal operations and implement data collection for reportable transactions.
What to do
Identify a Member State for registration and implement a data collection system to track reportable transactions of EU-resident users.
Deadline: Jan 1, 2026