White-label exchange providers supply the technology infrastructure that enables other companies to operate crypto exchanges under their own brand. This article examines the DAC8 compliance responsibilities in white-label arrangements.
The White-Label Model
In a white-label arrangement, the technology provider builds and maintains the exchange platform while the operating company (the licensee) manages the customer relationship, holds the regulatory license, and operates the exchange under its own brand. Users interact with the licensee's branded platform, often unaware of the underlying white-label provider.
Where DAC8 Responsibility Lies
Under DAC8, the reporting obligation falls on the entity that maintains the customer relationship and holds the regulatory authorization — in most cases, the licensee operating the branded exchange. The white-label technology provider is not the reporting entity unless it also directly serves end users.
However, the technology provider plays a critical role in enabling DAC8 compliance. The white-label platform must capture all required DAC8 data fields, support TIN collection and self-certification workflows, provide transaction classification capabilities aligned with DAC8 categories, and include XML report generation functionality in the DAC8/CARF format.
Shared Responsibility
In practice, DAC8 compliance in a white-label arrangement is a shared responsibility. The technology provider must build DAC8-compliant features into the platform, while the licensee must configure and use these features correctly, ensure their operational processes meet DAC8 requirements, and submit reports under their own name and regulatory registration.
Conclusion
White-label exchange providers must ensure their platforms support DAC8 compliance out of the box. Licensees must understand that using a compliant technology platform does not relieve them of their own DAC8 obligations — they remain legally responsible for the accuracy and timeliness of their reports.
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