MiCA Travel Rule and DAC8 Reporting: Synergies and Gaps

MiCA's implementation of the Travel Rule — requiring CASPs to share originator and beneficiary information for crypto-asset transfers — creates synergies with DAC8's transfer reporting requirements.

The Travel Rule Under MiCA

MiCA requires CASPs to collect and transmit information about the originator and beneficiary of crypto-asset transfers, including name, account number, and address or national identity number. This information must accompany the transfer and be made available to the receiving CASP.

Synergies with DAC8

Travel Rule data directly supports DAC8's transfer reporting by helping CASPs identify the counterparty in transfer transactions, classify transfers as user-to-user (reportable) versus user-to-own-wallet (potentially different treatment), and verify the consistency of user identification data across CASPs.

Gaps

Despite the synergies, gaps remain. Travel Rule data may not include Tax Identification Numbers or tax residency information. Transfers involving non-EU CASPs or self-hosted wallets may lack complete Travel Rule data. And the Travel Rule's implementation varies across jurisdictions, creating inconsistencies in data availability.

Practical Implications

CASPs should integrate Travel Rule data into their DAC8 reporting processes where available, but should not rely solely on Travel Rule information for DAC8 compliance. Additional data collection and verification steps will be needed, particularly for transfers involving self-hosted wallets or CASPs in jurisdictions with incomplete Travel Rule implementation.

Conclusion

The Travel Rule provides valuable data that supports DAC8 transfer reporting, but it is not a complete substitute for DAC8's specific requirements. CASPs should leverage Travel Rule data while building additional processes to fill the gaps.