2026 GuideHow to tokenize an asset in Spain, reviewed by three law firms. Download it

DAC8 cryptoassets: tax reporting 2026-2027

DAC8 obliges crypto exchanges and custodians to collect data from January 2026 and report to Hacienda in 2027. Who it affects, what data and what deadlines.

· 9 min read

DAC8 cryptoassets: tax reporting 2026-2027

DAC8 is the European directive that requires crypto-asset platforms to report user information to Spain's tax authority. Platforms have been collecting data since January 2026 and the first submission is in 2027. It affects anyone providing services on crypto-assets, and you should check whether your own activity falls within that scope.

You hear “DAC8” in a compliance meeting and you don't know if it applies to you, from when, or what you have to report. It happens a lot. The acronym sounds like something far away from Brussels, but the clock is already ticking: cryptoasset platforms have been collecting data from their users since January 2026, and the first submission to Hacienda arrives in 2027. If you issue or work with tokens, it's worth knowing where you fit.

This article explains what DAC8 is, who it applies to, the calendar and what it means for tokenization and security tokens. It does not repeat what is in MiCA in July 2026: here the focus is tax reporting.

What DAC8 is in one sentence

DAC8 is the European directive that obliges cryptoasset platforms to report to tax administrations who operates with crypto and how much, so that this information is exchanged between countries. In short, it is the directive on tax information exchange on crypto. Its formal name is Directive (EU) 2023/2226 of 17 October 2023, and it amends Directive 2011/16/EU on administrative cooperation in the field of taxation (DAC8, Directive (EU) 2023/2226; EUR-Lex).

The idea is simple. Hacienda already receives data from banks and financial institutions. With DAC8, cryptoassets enter that same automatic information circuit. What used to be off the radar now becomes reported.

Where “DAC” comes from

DAC is the English acronym for Directive on Administrative Cooperation. It has had several versions, each one broadening the scope. DAC8 is the eighth and the first to fully incorporate cryptoassets. It draws on the OECD CARF framework, the international standard for reporting crypto transactions.

Who DAC8 applies to

DAC8 obliges reporting crypto-asset service providers, the RCASPs, not the individual user or directly the token issuer. An RCASP is the crypto service provider required to report: the exchange, the custodian, the trading platform or the gateway that operates with crypto-assets for clients resident in the EU (DAC8, art. 8 bis quinquies and Annex VI; EUR-Lex).

The scope is broad. The directive not only covers providers already authorized under MiCA. It also reaches operators that provide cryptoasset services to EU residents even if they are not established in the Union. The criterion is where the client is, not where the platform is.

What an RCASP must report

The RCASP collects and reports identification data for each user and their transactions: purchases, sales, exchanges between cryptoassets and transfers. It applies due diligence procedures to verify the client's tax residence, similar to those already used in banking.

What it means for you

If you are a user, you do not file anything new because of DAC8: the obligation falls on the platform. But your transactions are reported, so consistency between what you declare and what Hacienda already knows matters more than before. If you operate a platform that touches cryptoassets, check whether you fall under the RCASP definition and prepare data collection. If you issue tokens, read the section on security tokens below: the nuance affects you.

Calendar: when it starts and when it is reported

Data collection obligations start on 1 January 2026; the first reporting and exchange of information takes place in 2027, covering fiscal year 2026. Member States had to transpose the directive before 31 December 2025 (DAC8, art. 2; EUR-Lex).

The scheme works like this: during 2026 platforms collect and record the information. At the end of the year, they report it to the tax administration, which then exchanges it with the rest of the EU countries. The first submission arrives in 2027.

MilestoneDateWhat happens
Adoption of DAC817 October 2023The Council approves Directive (EU) 2023/2226
Transposition deadline31 December 2025Member States adapt their national rules
Start of data collection1 January 2026RCASPs begin registering users and transactions
End of first year31 December 2026End of the data period to be reported
First reporting and exchange2027Platforms report and countries exchange information for the 2026 tax year

What it means for you

The preparation period has passed: collection is underway. If your activity qualifies as an RCASP, you should have due diligence procedures running now, not in 2027. Reporting for that year will reflect what you recorded throughout 2026.

How it intersects with Spanish tax forms

DAC8 does not replace the information obligations that already exist in Spain; it coexists with Forms 172, 173 and 721, and the transposition adjusts those forms. Spain already has its own information returns on crypto-assets.

  • Form 172. Information return on balances in virtual currencies. It is filed by providers that custody cryptographic keys on behalf of third parties (AEAT, Form 172).
  • Form 173. Information return on transactions with virtual currencies (purchase, sale, exchange, transfer), filed by those who provide such services (AEAT, Form 173).
  • Form 721. Information return on virtual currencies held abroad, filed by the holder when exceeding the threshold. The deadline runs from January 1 to March 31 of the following year (AEAT, Form 721).

Forms 172 and 721 are updated to include new products beyond virtual currencies, such as electronic money and central bank digital currencies, in line with the transposition of DAC8 (AEAT, campaign updates). The European and national pieces overlap, but they are not the same: check with your tax advisor which forms apply to you.

What it means for you

Do not assume that DAC8 exempts you from Spanish forms, or vice versa. The same transaction can create obligations through both channels. Keep records organized and check the calendar for each form, because the deadlines do not match.

What it means for tokenization and security tokens

DAC8 focuses on crypto-assets; security tokens are financial instruments and follow other reporting obligations, so DAC8 reporting does not cover them in the same way. Here is the nuance to keep clear.

A security token represents a transferable security. It is not a crypto-asset under MiCA, but a financial instrument regulated by the LMVSI (Ley 6/2023) and MiFID II. We explain in detail in why security tokens do not fall under MiCA. That separation also marks the tax terrain.

Reporting on securities already exists through other channels, the ones specific to financial instruments, not through the circuit that DAC8 launches for crypto-assets. If your project issues tokens that are securities, your reporting obligation travels along the financial instruments lane. If it issues or intermediates crypto-assets within the meaning of MiCA, then the DAC8 circuit does apply.

The border is not always clear

The classification of a token determines its tax and reporting regime. The same project can combine parts that are securities with parts that are crypto-assets. If you have doubts about where your issuance falls, start by understanding what asset tokenization is and check the glossary to fix the terminology before talking to your advisor.

What to do now

You do not need to solve everything today, but you do need to organize the first steps.

  • Classify your tokens. Determine whether they are securities (financial instruments) or crypto-assets. Everything else hangs on that. Review the border between security tokens and MiCA.
  • Check whether you are an RCASP. If you provide crypto-asset services to EU residents, review the definition and prepare data collection, which has been active since January 2026.
  • Cross-check with national forms. Verify whether Forms 172, 173 or 721 and their deadlines apply to you.
  • Separate crypto from securities in your records. Good records today prevent rushing in 2027. If you work on tokenization, start with this guide.
  • Talk to a tax advisor. Dates and forms change; confirm the current version and your specific case with the AEAT and a professional.

Frequently asked questions

What is DAC8?

It is Directive (EU) 2023/2226, which amends European administrative cooperation in tax matters to include crypto-assets. It obliges crypto platforms to report information on their users and transactions so that it can be exchanged between countries.

Who does DAC8 apply to?

Reporting crypto-asset service providers (RCASP): exchanges, custodians and platforms that operate with crypto-assets for EU residents. Individual users do not file anything new because of DAC8, although their transactions are reported.

When does it start to apply?

Data collection obligations begin on 1 January 2026. The first reporting and exchange of information takes place in 2027 and covers the 2026 tax year.

Does DAC8 affect security tokens?

Security tokens are financial instruments, not crypto-assets under MiCA, and follow their own information obligations. DAC8 reporting is designed for crypto-assets. That is why the classification of the token is the first thing to determine.

Does DAC8 replace Forms 172, 173 and 721?

No. The European obligation coexists with Spanish information returns. The transposition adjusts some forms, but the same transaction can generate obligations under both routes. Confirm it with your tax advisor.

Do I have to do anything if I am only a user of an exchange?

Under DAC8, the reporting obligation falls on the platform, not on you. Even so, your transactions are reported, so what you declare should be consistent with the information the tax authority receives.

Notice

Informational content. It does not constitute legal, tax or investment advice; consult a tax advisor. HokenFi is a software and infrastructure provider; it does not provide regulated services. Check the current version of the rules cited in the BOE and EUR-Lex.

Cited regulations

  • Council Directive (EU) 2023/2226 of 17 October 2023 amending Directive 2011/16/EU on administrative cooperation in the field of taxation (DAC8). EUR-Lex: https://eur-lex.europa.eu/legal-content/ES/TXT/?uri=CELEX:32023L2226
  • Council Directive 2011/16/EU of 15 February 2011 on administrative cooperation in the field of taxation. EUR-Lex: https://eur-lex.europa.eu/legal-content/ES/TXT/?uri=CELEX:32011L0016
  • Form 172. Information return on balances in virtual currencies. AEAT: https://sede.agenciatributaria.gob.es/Sede/todas-gestiones/impuestos-tasas/declaraciones-informativas/modelo-172-declaracion-informativa-sobre-virtuales.html
  • Form 173. Information return on transactions with virtual currencies. AEAT: https://sede.agenciatributaria.gob.es/Sede/procedimientoini/GI54.shtml
  • Form 721. Information return on virtual currencies held abroad. AEAT: https://sede.agenciatributaria.gob.es/Sede/procedimientoini/GI55.shtml
Get started

Do you have an asset to finance? Request your first offers.

Create your account, activate access and you will receive offers from law firms.