Council Directive 2023/2226 (DAC8) transposes the OECD's Crypto-Asset Reporting Framework into EU law. It entered force in Italy from 1 January 2026 via Legislative Decree 194/2025. The first reporting cycle covers calendar year 2026 transactions, with submissions due to the Agenzia delle Entrate by 30 June 2027.
DAC8 amends Directive 2011/16/EU on administrative cooperation in taxation. Article 8ad requires Reporting Crypto-Asset Service Providers (RCASPs) to identify reportable users and collect their identification data, balances, and transaction records. Reportable users are EU residents holding accounts or transacting above specified thresholds. Reportable transactions include crypto-to-fiat exchanges, crypto-to-crypto exchanges, and transfers. Legislative Decree 194/2025 sets Italian penalties at EUR 1,500 to EUR 15,000 for reporting or due-diligence failures.
CASPs licensed anywhere in the EU and serving Italian-resident clients must confirm their reporting infrastructure is operational for 2026 transactions. Required data points include customer identification, beneficial ownership for legal entities, transaction categorisation, and annual aggregates. Platforms previously reporting under domestic Italian tax rules must expand data collection to meet DAC8 scope. Italian CASPs that have not yet collected Italian tax identification numbers at client onboarding should address this before year-end 2026.
Italy transposed DAC8 ahead of several other EU member states. Cross-border data exchange between EU tax authorities first occurs by 30 September 2027. CASPs should confirm that existing onboarding templates capture all DAC8 data fields, including address data for clients resident in multiple EU states. ESMA's CASP register will inform the Agenzia delle Entrate matching process once the exchange infrastructure is active.
Licentium advises on crypto-asset tax reporting obligations and maintains a partner network including Italian counsel. Entities assessing DAC8 readiness, reviewing D.Lgs. 194/2025 implementation, or mapping CARF obligations across jurisdictions may contact us. Work we undertake includes RCASP classification analysis, DAC8 due-diligence policy design, Italian tax authority reporting structuring, and cross-border data-exchange preparation.