DAC8 Readiness Assessment: Where to Start

Before diving into DAC8 implementation, CASPs must evaluate their current state of readiness. A structured readiness assessment identifies gaps, prioritizes actions, and provides a realistic timeline for achieving compliance.

The Purpose of a Readiness Assessment

A DAC8 readiness assessment answers three fundamental questions. What does DAC8 require of your organization specifically? What capabilities do you already have in place? And what gaps must you close before the reporting deadline?

Without a readiness assessment, CASPs risk underestimating the scope of work, misallocating resources, discovering critical gaps too late to address, and building systems that do not meet the directive's actual requirements.

Key Assessment Areas

A comprehensive readiness assessment covers the following domains:

Data collection capabilities. Does your onboarding process capture all DAC8-required fields? Do you collect TINs from users in all relevant jurisdictions? Do you obtain self-certifications of tax residency? And is your data collection integrated or fragmented across multiple systems?

Transaction classification. Can your systems classify every transaction according to DAC8's four categories (fiat-to-crypto, crypto-to-crypto, transfer, payment)? Do you capture fair market values at the time of each transaction? And can you aggregate transaction data by user, transaction type, and crypto-asset?

Reporting infrastructure. Can you generate XML reports in the DAC8/CARF format? Do you have validation tools to check reports before submission? Have you identified the submission process for your home Member State? And do you have correction and resubmission capabilities?

Governance and processes. Is there a designated owner for DAC8 compliance? Are policies and procedures documented? Is staff trained on DAC8 requirements? And are there quality assurance processes for data and reports?

Conducting the Assessment

The most effective approach is to map each DAC8 requirement to your current capabilities, using a simple traffic light system. Green indicates the requirement is already met. Amber indicates partial capability that needs enhancement. Red indicates a significant gap that requires new development. This visual mapping provides management with a clear picture of the work ahead and supports resource allocation decisions.

Assessment Deliverables

The readiness assessment should produce a gap analysis document listing all identified gaps, a prioritized remediation plan with timelines, a resource estimate covering budget, personnel, and technology, and a risk register identifying the highest-priority risks and their mitigation strategies.

Conclusion

A readiness assessment is the essential first step in DAC8 implementation. CASPs that invest time in a thorough assessment will build more targeted, efficient compliance programs and avoid costly surprises later in the process.