The Kryptowerte-Steuertransparenz-Gesetz (KStTG) entered its first mandatory data collection year on 1 January 2026, implementing Council Directive (EU) 2023/2226 (DAC8) on administrative cooperation in the field of taxation. Calendar year 2026 is the first period for which reportable crypto asset transaction and account data must be collected. Crypto asset operators must transmit the collected data to the Bundeszentralamt für Steuern by 31 July 2027. The Federal Finance Ministry published technical guidance on 14 January 2026 specifying the mandatory CARF-XML schema for transmissions.
The KStTG implements Directive (EU) 2023/2226 of 17 October 2023, which amended Directive 2011/16/EU on administrative cooperation in the field of taxation to require reporting of crypto-asset transactions. A Kryptowerte-Betreiber (crypto asset operator) is defined in § 1 (9) KStTG as any entity providing crypto asset services on behalf of customers within the meaning of the DAC8 Directive. Reportable information covers account holder identification data, the types and quantities of crypto assets transacted or held, and their monetary values, structured in accordance with the OECD Crypto-Asset Reporting Framework (CARF).
Crypto exchanges, custodial wallet providers, and crypto asset service providers (CASPs) resident in or registered in Germany, or serving German account holders through entities subject to DAC8 in other EU member states, must review their technical systems to produce CARF-XML outputs matching the schema published by the Bundeszentralamt für Steuern. Providers whose systems do not currently capture the required account holder identification and transaction fields face a compliance gap for the 2026 collection year, which closes on 31 December 2026, with a first transmission deadline of 31 July 2027.
The definition of crypto asset operator in § 1 (9) KStTG excludes entities whose services do not involve the custody or transfer of crypto assets in the relevant sense, though boundary cases require careful legal analysis. The interaction between KStTG reporting obligations and MiCA authorisation data already collected by CASPs raises questions about whether a shared data architecture can serve both regulatory and tax reporting purposes. Operators active across multiple EU member states face the additional task of coordinating between national DAC8 implementing acts, which may differ in technical specifications.
Licentium advises digital asset businesses on DAC8 and KStTG compliance in Germany and across the EU. Work we undertake includes CARF-XML technical implementation assessments, crypto asset operator scope analysis, MiCA CASP authorisation support, and cross-border DAC8 coordination for multi-jurisdiction operators.