DAC8 Continuous Improvement: Learning from Each Reporting Cycle

DAC8 compliance is not a one-time project — it is an ongoing operational commitment that improves with each reporting cycle. This article describes a continuous improvement approach to DAC8 compliance.

Post-Cycle Review

After each annual reporting cycle, CASPs should conduct a structured review that examines what went well, identifying processes and systems that performed effectively, what went wrong, documenting errors, delays, and unexpected challenges, root causes, analyzing why problems occurred and what systemic factors contributed, and lessons learned, capturing insights that should inform future cycles.

Key Metrics

Track metrics that measure compliance quality and operational efficiency, including report accuracy rate (percentage of submitted data that did not require correction), on-time submission rate, look-back completion rate for existing users, user data quality scores (TIN completeness, self-certification status), QA findings by category, and processing time from period end to report submission.

Improvement Actions

Common improvement actions after the first reporting cycle include refining transaction classification rules based on real-world edge cases, improving TIN validation logic for jurisdictions where errors were frequent, enhancing the onboarding flow to increase data collection rates, updating training materials based on staff feedback, and automating manual steps that caused delays or errors.

Regulatory Evolution

DAC8 requirements will evolve over time as Member States refine their transposition legislation, the European Commission issues guidance and interpretations, tax authorities publish technical specifications and business rules, and the OECD updates the CARF standard.

CASPs must build regulatory monitoring into their continuous improvement process, tracking changes that affect their reporting obligations and updating their systems and processes accordingly.

Conclusion

Continuous improvement transforms DAC8 compliance from a burdensome obligation into a mature, efficient operational capability. CASPs that embrace this mindset will achieve higher compliance quality at lower cost over time.