Payment service providers (PSPs) that facilitate crypto-asset payments — enabling users to pay for goods and services using crypto-assets — face specific DAC8 obligations related to the retail payment transaction category.
Payment Transactions Under DAC8
DAC8's fourth reportable transaction category covers retail payment transactions, where a crypto-asset is used to pay for goods or services. PSPs that facilitate these transactions must report the aggregate gross amount of crypto-assets used for payments, the number of payment transactions, and the fair market value of the crypto-assets at the time of payment.
Dual Reporting Considerations
In a typical crypto payment scenario, the PSP may facilitate both a crypto-to-fiat conversion (to settle the merchant in fiat currency) and the underlying payment transaction. Both elements may be reportable under different DAC8 categories — the conversion as a fiat-to-crypto exchange and the payment as a retail transaction.
PSPs must carefully classify each component of the payment process to avoid double-counting or underreporting.
Merchant Reporting
PSPs must determine whether the merchant is also a reportable user under DAC8. If the merchant receives crypto-assets (rather than fiat settlement), the receipt of crypto-assets by the merchant may constitute a reportable transaction from the merchant's perspective.
Conclusion
PSPs facilitating crypto payments must navigate the complexity of multi-component transactions and ensure that both payment and conversion elements are correctly classified and reported under DAC8.
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