DAC8 Implementation Roadmap: A 12-Month Plan

This article provides a practical 12-month implementation roadmap for CASPs preparing for DAC8 compliance. The timeline assumes a start date approximately 12 months before the first reporting period.

Months 1-2: Foundation

Complete the readiness assessment and gap analysis. Secure management commitment and budget approval. Designate the DAC8 compliance owner and assemble the project team. Engage external advisors if needed for legal interpretation and technical implementation. And begin the regulatory monitoring process to track national transposition developments.

Months 3-4: Design

Design the enhanced onboarding flow incorporating TIN collection and self-certification. Define transaction classification rules for all supported crypto-assets and transaction types. Specify the XML reporting system requirements. Design the look-back process for existing users. And establish data governance policies for DAC8 data.

Months 5-7: Build

Implement the enhanced onboarding flow. Build or configure the transaction classification and aggregation engine. Develop the XML report generation system. Create TIN validation logic for all relevant jurisdictions. Build the correction and resubmission workflow. And develop internal validation tools for pre-submission report checking.

Months 8-9: Test

Conduct end-to-end testing of the complete DAC8 reporting process. Generate test reports using sample data. Validate test reports against the XML schema and known business rules. Test the correction and resubmission process. Conduct user acceptance testing for the enhanced onboarding flow. And perform stress testing with realistic transaction volumes.

Months 10-11: Deploy and Train

Deploy the enhanced onboarding flow to production. Launch the look-back campaign for existing users. Train compliance staff on DAC8 procedures and tools. Train customer support staff on handling DAC8-related user queries. Finalize documentation of all procedures and policies. And conduct a final dry run of the report generation process.

Month 12: Go-Live

DAC8 obligations take effect. Begin collecting all required data from new and existing users. Monitor the look-back campaign progress. Track any regulatory updates or guidance from the competent authority. And begin accumulating transaction data for the first reporting period.

Conclusion

A 12-month implementation timeline is ambitious but achievable for well-organized CASPs. The key is starting early, maintaining momentum, and testing thoroughly before go-live.