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CARF and DAC8 scope test

Two questions decide whether you report: are you a Reporting Crypto-Asset Service Provider, and is the asset a Relevant Crypto-Asset. Obligations took effect on 1 January 2026, and being unlicensed does not put you outside them. This works through both.

OECD CARF · DAC8 — Directive (EU) 2023/2226 · RCASP test · asset exclusions · nothing stored

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Answer for your business and for one type of crypto-asset. Both halves must be satisfied for a reporting obligation to arise — an in-scope provider handling only excluded assets reports nothing, and an out-of-scope business handling relevant assets reports nothing either.

Part 1 — Are you a Reporting CASP?

CARF Section IV · DAC8

Any one service, provided as a business, brings you into scope. Authorisation is not the test.

Do you effectuate exchanges between crypto-assets and fiat currency for or on behalf of customers?Buys and sells.
Do you effectuate exchanges between one or more forms of crypto-asset?Crypto-to-crypto trades.
Do you effectuate transfers of crypto-assets for customers, on or off platform?Includes wallet providers and transfer services, not only exchanges.
Do you serve customers resident in the EU, or otherwise operate in an implementing jurisdiction?DAC8 has extraterritorial reach. A non-EU provider serving EU customers can be pulled into scope.

Part 2 — Is the asset a Relevant Crypto-Asset?

CARF Section IV · exclusions

The definition is broad and the exclusions are narrow. Note that an exclusion from CARF is often a reallocation to the amended CRS, not an exemption.

Is it a central bank digital currency?Excluded from CARF — but brought within the amended CRS instead.
Is it a Specified Electronic Money Product?Represents a single fiat currency and is redeemable at any time in that same currency. Excluded from CARF because it sits within the amended CRS.
Have you adequately determined that it cannot be used for payment or investment purposes?The commentary addresses closed-loop assets usable only within a fixed network or environment. The determination has to be made and evidenced, not assumed.
Does it rely on cryptographically secured distributed ledger technology or similar?The distinguishing feature underpinning creation, holding and transferability. Stablecoins, many NFTs and crypto-form derivatives can all fall in scope where the conditions are met.
What this means: an indicative scope result for one business and one asset type. Jurisdictions have implemented CARF on different timelines and with differing interpretations, and several have published no guidance at all — so local implementing rules govern. DAC8 uses MiCA definitions for service providers and crypto-assets, which does not always align with an OECD-only reading. This is not tax advice.

In scope means transaction-level reporting, per jurisdiction. The CARF and DAC8 module takes user and transaction data, applies due diligence outcomes, validates and produces the reporting file — with a free tier to start.

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Three misreadings

Where firms place themselves out of scope wrongly

Licensing

“We are not authorised, so it does not apply”

The RCASP test is about what you do as a business, not what permission you hold. An unlicensed platform effectuating exchanges or transfers can be in scope, and MiCA authorisation is a separate question with a separate purpose.

Geography

“We are not established in the EU”

DAC8 reaches beyond the Union. A provider outside the EU that performs crypto-asset services for EU-resident users can be brought into scope, which is why Swiss and Liechtenstein providers have been planning for it.

Exclusions

“CBDCs are carved out”

They are carved out of CARF and brought into the amended CRS instead. The same is true of specified electronic money products. The carve-out reallocates the reporting rather than removing it.

Rules reviewed 21 August 2026 · OECD Crypto-Asset Reporting Framework · Council Directive (EU) 2023/2226 (DAC8), applicable from 1 January 2026

Scope

What this test does

It applies the two gateway questions. Everything past the gateway — due diligence, self-certifications, transaction reporting — is the actual compliance work.

It doesTest both gateways

  • Tests the RCASP definition across exchanges, crypto-to-crypto trades and transfers.
  • Accounts for the extraterritorial reach of DAC8 to providers outside the EU.
  • Applies the three CARF exclusions, and says where each one reallocates to.
  • Requires both gateways to be satisfied before a reporting obligation arises.
  • Separates a clear result from one resting on unresolved questions.
  • Sets out the reportable transaction types that follow.

It does notApply local implementation

  • Reflect any particular jurisdiction’s implementing legislation, timeline or guidance.
  • Decide whether a given NFT or token satisfies the CARF conditions.
  • Determine whether a DeFi arrangement has a provider capable of being an RCASP.
  • Apply the amended CRS to assets excluded from CARF.
  • Handle due diligence, self-certification validity or reportable user identification.
  • Produce anything you can file, or constitute tax advice.

Excluded from CARF often means in scope for CRS

The amended CRS pulls certain e-money products and CBDCs into the financial account regime, along with indirect crypto exposure through derivatives and investment vehicles. Classification decides which framework, rarely whether.

CRS entity classification →

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Questions

About CARF and DAC8 scope

Who is a Reporting Crypto-Asset Service Provider?

Any individual or entity that, as a business, provides a service effectuating exchange transactions in relevant crypto-assets for or on behalf of customers. In practice that covers exchanges, wallet providers, transfer services and potentially some DeFi arrangements. Holding a licence is not the test, and being unlicensed is not a defence.

Does it apply to providers outside the EU?

It can. DAC8 has extraterritorial reach: non-EU providers performing crypto-asset services for users resident in the Union are pulled into scope. Providers authorised under MiCA are already registered in the EU and are subject to DAC8 in their member state of residence.

Which assets are excluded?

Three categories: central bank digital currencies, specified electronic money products, and crypto-assets for which the provider has adequately determined that they cannot be used for payment or investment purposes. That last category is addressed in the commentary and covers closed-loop assets usable only within a limited fixed network.

Are excluded assets outside reporting altogether?

Usually not. The CRS was amended alongside CARF to bring certain electronic money products and CBDCs into the financial account reporting regime, and to cover indirect crypto exposure through derivatives and investment vehicles. The two standards have interaction rules to avoid duplication, which is why accurate classification matters more than finding an exclusion.

What has to be reported once in scope?

Exchanges between relevant crypto-assets and fiat currency, exchanges between crypto-assets, transfers of relevant crypto-assets, and reportable retail payment transactions above USD 50,000. Reporting is to the domestic tax authority under the local implementation, which then exchanges the information.

Do you store my answers?

No. Everything is held in the page and discarded when you close or reload it.

Obligations began on 1 January 2026.

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