DAC8 Reporting Deadlines: Key Dates by Member State

Meeting DAC8 reporting deadlines is critical. This article outlines the key dates in the DAC8 reporting calendar and explains how deadlines may vary across EU Member States.

Universal Dates

Several dates are fixed by the directive and apply uniformly across all Member States:

December 31, 2025: Deadline for Member States to transpose DAC8 into national law.

January 1, 2026: DAC8 becomes operational. CASPs must begin applying due diligence procedures and collecting required data from this date.

Calendar year 2026: The first reporting period. CASPs must collect and retain data on all reportable transactions and users throughout the year.

Member State-Specific Deadlines

The deadline for submitting annual reports to the competent tax authority is determined by each Member State. While the directive indicates that reporting should occur within the first quarter of the year following the reporting period, specific deadlines vary.

Most Member States are expected to set their deadline at January 31 of the following year, consistent with the CARF standard. However, some may allow until March 31 or set different dates. CASPs operating across multiple jurisdictions must monitor each Member State's transposition legislation for the specific deadline.

Look-Back Deadlines

For existing users (those who opened accounts before January 1, 2026), Member States may set specific deadlines for completing the look-back review to collect missing TINs and self-certifications. These deadlines are typically within the first reporting year but may extend to 12 months after the directive takes effect.

Exchange Deadlines

After receiving reports from CASPs, tax authorities must exchange the information with other Member States. The directive specifies that the first automatic exchange should take place by September 30, 2027, covering the 2026 reporting period.

Practical Timeline for CASPs

A practical DAC8 compliance timeline includes: system readiness by December 31, 2025, data collection begins January 1, 2026, look-back reviews completed during 2026, first report generated in January 2027, first report submitted by the Member State deadline (likely January 31, 2027), and corrections submitted as needed throughout 2027.

Conclusion

CASPs must track both the universal DAC8 dates and the specific deadlines set by each Member State where they report. Building a compliance calendar that accounts for all relevant dates is an essential project management tool for DAC8 implementation.