As the industry approaches a new frontier in global tax transparency, the panel “CARF and DAC8 Operational Readiness: Preparing for Compliance in 2025” at the Digital Accord Summit, offered a grounded, highly practical discussion on what lies ahead. Moderated by Erin Fennimore, VP of Tax Solutions, Taxbit, and experts including –
- Barbara Edelmann, VP Finance & Tax, Bitpanda
- Dorina Juhasz, Strategic Projects, Bitvavo
- David Wren, Partner, Product & Operational Tax, KPMG UK
To explore what readiness actually looks like in the face of evolving regulation and operational uncertainty.
The Clock Is Ticking — And the Frameworks Are Evolving
The panel kicked off with a sense of urgency. Implementation deadlines are approaching fast, but clarity is still elusive. Wren highlighted a key distinction: while reporting under DAC8 and CARF begins in 2027, the operational requirements go live in January 2026. That means processes like collecting tax residence certifications and TINs must already be in place.
“We don’t have two years. We’ve got about eight months,” Wren cautioned, referring to the compressed implementation window. For many firms, that’s half the time traditional financial institutions had under earlier frameworks like CRS.
Onboarding: A Make-Or-Break Moment
A recurring theme throughout the session was the criticality of customer onboarding. Unlike AML/KYC processes, failure to collect tax self-certifications can trigger serious consequences — from account blocks to misreporting.
As Wren noted, “If you make one mistake around the tax onboarding, that one customer is going to be reported to an incorrect tax authority… and the risk reverberates throughout the organization.” In short: this is not an area where duct-taping compliance to existing processes will work.
Juhasz echoed the concern, stressing the real-world impact: “Every new screen in the onboarding flow is an extra drop-off point.” The friction introduced by DAC8 and CARF is not just a regulatory headache — it directly affects user experience and retention.
System Challenges and Transaction Volume
Operationally, the biggest hurdles lie in data management and scale. While crypto-native companies often benefit from more streamlined systems, the complexity and volume of crypto transactions pose new challenges — especially when layered with eight distinct transaction types per asset under CARF.
“There’s no way to take a cut of the data at year-end,” Wren explained. “We had to go transaction by transaction… It’s the only way.” And for exchanges that list thousands of tokens or support DeFi products, the reporting burden is even heavier.
Jurisdictional Uncertainty and the Local Layer
Adding another layer of complexity is the lack of harmonization across jurisdictions. With varying implementation timelines and interpretations of the rules, panelists expressed concern about unequal enforcement and the creation of competitive disadvantages.
Edelmann summed it up succinctly: “We don’t have legal wording yet for many key jurisdictions. It’s April. I get tons of questions from UX and I have to answer with assumptions.”
Taking the Customer Along the Journey
With all the technical and legal nuances, it can be easy to lose sight of the human factor — the end users. But this panel didn’t. Both Bitpanda and Bitvavo emphasized that success depends on proactively educating customers and avoiding surprises.
“This is step zero,” said Juhasz. “They need to know why we’re asking for this data… and how we’re handling it.”
It’s not just about ticking regulatory boxes — it’s about building trust in a space already grappling with transparency challenges.
Final Thoughts: There’s No Playbook — Yet
The panel closed with a clear consensus: there’s no one-size-fits-all solution. Readiness will require cross-functional collaboration, constant iteration, and engagement with tax authorities where possible.
Wren left the audience with pragmatic advice: “Go and talk to your tax authority. They’ll bite your hand off for information right now.”
In a world of moving targets, ambiguity, and compressed timelines, this panel was a timely reminder that readiness isn’t about being perfect — it’s about being intentional, proactive, and transparent.
To learn more, watch the full panel discussion on demand today.
