How MiCA Authorization Impacts DAC8 Reporting

The process of obtaining MiCA authorization has direct implications for a CASP's DAC8 obligations. This article examines how the authorization timeline and requirements affect DAC8 compliance planning.

Pre-Authorization Period

CASPs operating under MiCA's transitional provisions — those that were active before MiCA took full effect and are awaiting authorization — are still subject to DAC8 from January 1, 2026. The lack of a formal MiCA license does not exempt a CASP from DAC8 obligations if it is providing reportable services.

Authorization as a Compliance Catalyst

The MiCA authorization process requires CASPs to demonstrate robust governance, risk management, and operational capabilities. Many of these capabilities — particularly in data management, record-keeping, and compliance monitoring — are directly relevant to DAC8. CASPs should use the MiCA authorization process as an opportunity to build DAC8 compliance into their operational framework from the start.

Post-Authorization Obligations

Once authorized, MiCA-licensed CASPs are subject to ongoing supervision that may include assessments of DAC8 compliance. National supervisory authorities may coordinate with tax authorities to ensure that licensed CASPs are meeting all their regulatory and tax obligations.

Conclusion

MiCA authorization and DAC8 compliance should be planned and implemented together. CASPs that treat them as separate projects risk duplication of effort and potential compliance gaps.