DAC8 applies to the 2026 reportable period. Under the Directive, reporting crypto-asset service providers submit the first 2026 information by 31 January 2027, and Member States exchange that information by 30 September 2027. Due-diligence obligations operate during the reportable period; the exact German filing mechanics must follow the national implementation. For German holders this changes no rate and no deadline. It changes whose numbers the Finanzamt holds first — and the BMF letter of March 2025 already delivered the other jaw of the same clamp.
A clamp with two jaws
Jaw one: the platform report. Exchanges and brokers report identity, tax number and transaction volumes — bundled, machine-readable, yearly. Jaw two: the cooperation duties. The BMF letter of 6 March 2025 demands complete records from the holder — coin, quantity, timestamps, prices, fees, per transaction and per wallet. As the first 2026 reports and the subsequent EU exchange move through 2027, the Finanzamt can hold both: the platform's third-party data and the yardstick your own records are measured against. A return that deviates from the platform report and cannot be explained from your own records is the new standard case for an inquiry.
Until now, the Finanzamt proved something was missing. Soon, you explain why your numbers differ from the report. The burden of proof does not shift legally — but it does practically.
Who it reaches first
Tax-free post-year sales become visible — and with them the question whether the year had truly run: acquisition date and FIFO chain become questions of evidence. Reward streams become matchable — reported receipts against declared other income, the €256 edge included. And for anyone with entirely undeclared years, the gap acquires a delivery date: the self-disclosure fails on the discovery blocking ground, and from the first reporting wave, "discovered" is for many constellations no longer a question of whether but of sorting date.
The honest read
- The correctly declared: bring records to BMF standard. The report will come; your own documentation decides whether it is a confirmation or a clarification case.
- Be able to prove tax-free sales. "Period expired" is an assertion — acquisition proof, price and wallet chain are the evidence.
- Keep reward logs complete. The matching runs on receipts; your own log must pass it.
- Close undeclared years before the reporting/matching sequence advances. Reconstruction, the § 153-or-§ 371 threshold question, filing — in that order, with counsel, before the reporting wave. Afterwards the data matching sorts, not the holder.
Why the line stays "watch"
The first reporting cycle has not yet run, and how the offices operationalise the first wave is forecast. The dates stand; the practice follows. Updates flow through the change log.
A position note on a reporting system before its first cycle. It is not advice on your affairs, and reading it creates no professional relationship.