Building separate compliance programs for MiCA and DAC8 is inefficient and increases the risk of inconsistencies. This article provides a practical guide to aligning both programs.
Unified Governance
Establish a single compliance governance structure that covers both MiCA and DAC8. This includes a designated compliance officer with responsibility for both frameworks, a compliance committee that reviews both regulatory and tax reporting obligations, integrated risk assessments that consider both MiCA and DAC8 requirements, and unified policies and procedures that address both sets of obligations.
Integrated Onboarding
Build a single onboarding flow that collects all data required by both MiCA and DAC8. The flow should capture MiCA KYC data (identity verification, source of funds), DAC8 tax data (TIN, self-certification), in a seamless user experience that minimizes friction and maximizes data quality.
Shared Technology
Use shared technology infrastructure for data storage, transaction monitoring, reporting, and record-keeping. A unified data warehouse that serves both MiCA supervisory reporting and DAC8 tax reporting is more efficient and reduces the risk of data inconsistencies.
Coordinated Testing
Test compliance processes holistically, verifying that onboarding correctly captures all MiCA and DAC8 data, transaction classification aligns with both frameworks' requirements, reporting outputs satisfy both MiCA and DAC8 formats, and correction procedures work for both supervisory and tax reports.
Conclusion
Aligning MiCA and DAC8 compliance programs is not just an efficiency measure — it reduces operational risk, improves data quality, and creates a more sustainable compliance operation. CASPs should treat dual compliance as a single integrated project.
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