MiCA-Licensed CASPs and DAC8 Obligations: What You Need to Know

Obtaining a MiCA license is a significant milestone for any CASP. But it also triggers a set of DAC8 obligations that licensed entities must understand and prepare for.

Automatic DAC8 Coverage

Any entity that holds or is required to hold a MiCA authorization automatically falls within the scope of DAC8. There is no separate registration or opt-in process for DAC8 — the obligation follows directly from the CASP's regulatory status under MiCA.

This means that from the moment a CASP receives its MiCA authorization (or from January 1, 2026, if already operating under transitional provisions), it must comply with all DAC8 requirements, including customer due diligence, data collection, and annual reporting.

What MiCA Already Requires

MiCA-licensed CASPs already collect much of the information needed for DAC8 compliance. Identity verification under MiCA's KYC requirements covers most of DAC8's identification fields. Transaction records maintained for MiCA's reporting and market surveillance purposes contain the raw data needed for DAC8 reports. And governance frameworks established for MiCA include compliance functions that can be extended to cover DAC8.

What DAC8 Adds

Despite the overlap, DAC8 introduces requirements that go beyond MiCA. Tax Identification Numbers are not required by MiCA but are mandatory under DAC8. Self-certifications of tax residency are a DAC8-specific requirement with no MiCA equivalent. The annual XML report in DAC8/CARF format is a new deliverable that MiCA does not require. And the look-back process for existing users is a DAC8 obligation that applies regardless of when the user was onboarded under MiCA.

Building an Integrated Compliance Program

The most efficient approach is to build an integrated compliance program that addresses both MiCA and DAC8 from a single operational framework. This includes unified onboarding flows that capture both MiCA KYC and DAC8 tax data, shared data repositories that serve both regulatory and tax reporting needs, coordinated governance with clear ownership of both MiCA and DAC8 obligations, and integrated training programs that cover both sets of requirements.

Conclusion

MiCA authorization and DAC8 compliance are inseparable for EU CASPs. Building an integrated approach from the outset saves time, reduces costs, and ensures consistent compliance across both frameworks.