DAC8 and Stablecoins: Reporting Requirements

Stablecoins occupy a unique position within DAC8's reporting framework. As crypto-assets designed to maintain a stable value relative to a reference asset, they present specific classification and reporting challenges that CASPs must address.

Stablecoin Classification Under DAC8

DAC8 classifies stablecoins according to MiCA's taxonomy, which distinguishes between two main types:

Asset-referenced tokens (ARTs) maintain their value by referencing a basket of assets, which may include multiple fiat currencies, commodities, or other crypto-assets. Examples include tokens backed by a combination of currencies and gold.

E-money tokens (EMTs) maintain their value by referencing a single official currency. The most prominent examples include USDC (referenced to the US dollar), EUROC (referenced to the euro), and similar fiat-backed stablecoins.

Both ARTs and EMTs are explicitly within the scope of DAC8 and must be reported when transacted through a CASP.

Why Stablecoins Present Unique Reporting Challenges

Stablecoins are often used as intermediary assets in trading workflows. A user might convert fiat to USDT, then use USDT to purchase Bitcoin, then sell Bitcoin for USDC, and finally convert USDC back to fiat. Each of these steps is a separate reportable transaction under DAC8.

This creates several challenges for CASPs. Transaction volumes involving stablecoins are typically much higher than for other crypto-assets, as traders use them as a base currency for multiple trades. The fair market value calculation for stablecoins should be straightforward (close to the reference currency value) but may fluctuate during periods of market stress, requiring CASPs to capture the actual market value at the time of each transaction rather than assuming a 1:1 peg.

Stablecoin-to-stablecoin conversions (for example, USDT to USDC) are reportable crypto-to-crypto exchanges even though both assets reference the same fiat currency. CASPs must report these transactions even when the economic substance appears minimal.

Reporting Requirements

For each stablecoin transaction, CASPs must report the specific stablecoin involved (identified by name and distributed ledger identifier), the MiCA classification (ART or EMT), the transaction type (fiat-to-stablecoin, stablecoin-to-crypto, stablecoin-to-stablecoin, etc.), the aggregate amounts in the reporting currency, and the fair market value at the time of transaction.

CASPs must ensure that their transaction classification systems correctly identify and categorize stablecoin transactions separately from other crypto-asset transactions.

Stablecoin Transfers

Stablecoins are frequently used for value transfer between platforms and between users. These transfers are reportable under DAC8's transfer category. CASPs should pay particular attention to stablecoin transfers as they may represent payment transactions (using stablecoins to pay for goods or services) rather than simple transfers between accounts.

Algorithmic Stablecoins

Algorithmic stablecoins — those that maintain their peg through algorithmic mechanisms rather than asset reserves — present additional classification challenges. Their MiCA classification may be ambiguous, and their value stability cannot be guaranteed. CASPs should assess each algorithmic stablecoin individually to determine its DAC8 classification and reporting treatment.

Conclusion

Stablecoins are firmly within DAC8's scope and generate significant reporting volumes due to their role as intermediary trading assets. CASPs must build reporting systems that can handle the high transaction volumes associated with stablecoin trading while correctly classifying each transaction and capturing accurate fair market values.