Crypto exchanges represent the largest category of MiCA-licensed CASPs and generate the highest volume of DAC8-reportable transactions. This article addresses the specific compliance considerations for exchanges.
Exchange-Specific Challenges
Exchanges face unique DAC8 challenges due to the volume and variety of transactions they process. High transaction volumes require robust aggregation systems. Multiple trading pairs create complex reporting matrices. Market-making activities may generate reportable transactions distinct from client trades. And margin trading and derivatives may involve crypto-asset movements that require careful classification.
Leveraging Exchange Infrastructure
Exchanges typically have sophisticated trading engines, order management systems, and data warehouses that can be adapted for DAC8 reporting. The key is ensuring that these systems capture and retain all data fields required by DAC8, including fair market values at the time of each transaction.
Practical Recommendations
Exchanges should map their existing data architecture to DAC8's reporting requirements, identify gaps in data capture (particularly TINs and self-certifications), build aggregation logic that correctly classifies and summarizes transactions by type and crypto-asset, and implement pre-submission validation to catch errors before filing.
Conclusion
Exchanges are well-positioned for DAC8 compliance due to their existing data infrastructure, but the volume and complexity of their transaction data requires careful planning and robust systems.
Preparing for DAC8?
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