Crypto bookkeeping update: September 2026

This is the first issue of a format that appears when something has moved: five things that changed for anyone who has to bring crypto payments into German books, whether in their own company or for clients. Every claim carries its source, forecasts are labelled as forecasts, and where nothing happened, nothing gets inflated to fill space. If you are smarter after five minutes, the issue has done its job.

Stripe now lets machines pay

Since 27 August, Stripe settles payments that are initiated by AI agents and paid in stablecoins, and German companies are explicitly among the possible recipients (ad-hoc-news). Think of it what you will, and today's volumes are small. What deserves attention is the bookkeeping mechanics underneath: an agent buying software access, data, or ad inventory for its operator produces many small payments with no human sender, no conventional order, and often no invoice in the familiar sense. The payment receipt itself is then the most complete evidence that exists.

What to do now: nothing rash, but look honestly at your own evidence chain. Copying payment receipts from an exchange export into Excel works at twenty inflows a month. At two hundred machine-initiated micro-amounts the same process does not degrade gracefully; it fails within a month.

79 MiCAR authorisations: Germany is the EU's largest market

BaFin has now authorised 79 providers under the EU's MiCAR, more than any other supervisor in the EU; France follows with 35, the Netherlands with 29 (Trending Topics). The composition is the notable part: a substantial share of the authorisations belongs not to crypto startups but to banks, savings-bank institutions and investment firms that filed crypto trading as an add-on business. Germany's financial sector applied as a bloc while others are still debating.

Update, 9 September 2026: the figure of 79 was the count at the time of this post. We have since worked through the ESMA register under Art. 109 MiCAR ourselves: BaFin now accounts for 89 of the 346 authorisations across the European Economic Area, spread across 86 firms. The ranking is unchanged, France 35, the Netherlands 29. The full, maintained list is now in our CASP register.

Update, 3 October 2026: the register has moved again since. As of 24 September 2026 BaFin accounts for 99 of the 364 authorisations, spread across 96 firms; France 36, the Netherlands 29. The additions are Deutsche Bank and nine cooperative banks.

What to do now: for tax firms, a second look at the client base is worth it. Once a client's own house bank offers crypto custody, the topic no longer arrives as an exotic request from a lone founder; it arrives as a bank statement of a perfectly ordinary GmbH.

DAC8: from mid-2027 the tax office compares notes

Since 1 January, crypto-asset service providers have been recording their customers' master data and transactions under Germany's crypto tax transparency act; the first reports reach the Federal Central Tax Office by mid-2027 (kleinstb.de). That deserves a moment's thought. Until now, the tax administration knew about crypto holdings essentially what was declared. From mid-2027 it holds a second, independently collected data trail, and the obvious administrative step is an automated comparison of the two. Nobody has to go looking for a gap between the books and the reported data anymore; it surfaces on its own.

What to do now: fiscal year 2026 is the first one that gets reported, and it is already running. Booking "as always, we'll sort it out at year-end" builds up exactly the differences that become visible in 2027. Cleaning up retroactively costs a multiple of booking cleanly as you go.

Euro stablecoins: the euro stays a spectator in the stablecoin market

By our ongoing analysis of public market data, the total circulation of all euro stablecoins stood at roughly 760 million US dollars at the start of September (as of 2026-09-01, own analysis). For scale: the two large dollar stablecoins alone move in the hundreds of billions. That ratio has barely shifted for months, banking consortium and MiCAR notwithstanding.

What to do now: as long as payments arrive in USDC or USDT, every receipt has to be valued in euros: the crypto-asset's market rate from a named source (BMF letter of 06.03.2025, Rz. 43), and for USD-pegged tokens the USD/EUR conversion at the ECB reference rate on top. Document both steps, keep the method.

Practice note: the Belegfeld 2 workaround and its limit

In DATEV practice, crypto is often represented via a workaround: a euro booking on a clearing account, the crypto details carried as text in document field 2 (P. Hornung, accounting for cryptocurrencies in DATEV). That is not a mistake; it works, and many firms have run this way for years. But a text field answers no questions: which rate was used, from which source, fixed at which moment, and why this account? A tax audit rarely asks what was booked. It asks why that way, and the workaround has no stored answer to that why.

What to do now: at minimum, record the rate source and valuation moment per booking, wherever you keep it. Anyone staying with the workaround should describe it in their Verfahrensdokumentation, so it reads as a deliberate procedure rather than an accident.

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Carefully researched, but no substitute for tax or legal advice in an individual case.