DAC8 and MiCA: Shared Data Requirements

DAC8 and MiCA require CASPs to collect overlapping sets of data from their users. This article maps the shared data requirements and identifies opportunities for efficiency.

Overlapping Data Fields

Both frameworks require collection of the user's full legal name, date of birth, residential address, nationality or country of incorporation, and identity document details. These fields form the core of KYC data and are collected during the onboarding process under both MiCA and DAC8.

DAC8-Specific Fields

Fields required only by DAC8 include Tax Identification Numbers for each jurisdiction of tax residence, self-certifications of tax residency, and specific transaction categorization (fiat-to-crypto, crypto-to-crypto, transfer, payment) in the DAC8/CARF format.

MiCA-Specific Fields

Fields required primarily by MiCA include source of funds documentation, risk assessment scoring, politically exposed person (PEP) screening results, and sanctions screening results.

Unified Data Model

CASPs should build a unified data model that captures all fields required by both frameworks in a single onboarding flow. This avoids asking users for the same information twice and ensures that all regulatory requirements are met from a single source of truth.

Conclusion

The significant overlap between MiCA and DAC8 data requirements creates a clear case for unified data collection. CASPs that build integrated systems from the outset will achieve compliance more efficiently and provide a better user experience.