The situation, in four facts
| 01.01.2026 | Collection duty running: crypto-asset service providers have been recording user and transaction data since the start of the year (KStTG). |
| 31.07.2027 | First report to the Federal Central Tax Office, covering reporting year 2026. |
| CARF XML v1.5 | The prescribed format (BMF letter of 14.01.2026). No form-based route has been published. |
| 79 | Authorised crypto-asset service providers in Germany, the largest pool in the EU. Non-MiCA crypto operators with EU customers must report as well. |
What the workflow covers
The XML is the last link of a chain that starts much earlier. The workflow we are building follows the chain in the order it actually occurs in operation:
1. Due diligence & self-certifications. Reporting starts long before the XML: collecting self-certifications, sanity-checking residencies and TINs, chasing gaps. That is the real workload, and it runs all year.
2. Consolidating transaction data. Acquisitions, disposals, transfers per user and crypto-asset, aggregated the way the law prescribes, from the systems where they actually live.
3. Validation before filing. An XML the BZSt rejects is not a report. Structural and plausibility checks against the CARF schema before anything leaves the house.
4. CARF XML & the corrections cycle. Producing the file for the DIP mass-data interface or the portal upload, and the part nobody talks about: corrections and cancellations when data changes after the fact.
For tax firms
Many smaller reporting entities will hand the task to their tax advisor. Stablewerk is built for exactly that: one advisor, many clients, one tool to run, check and file reports per client. If your firm serves crypto clients and DAC8 is rolling toward you, talk to us.
What the DAC7 precedent says about enforcement
DAC7, the directly comparable reporting duty for platform operators, has applied since 2023. Answering a parliamentary question, the federal government published its enforcement figures (Bundestag Drucksache 20/14937, 10.02.2025): Germany transmitted 44,376 datasets and received 448. Fourteen platform operators had been audited at that point, and no breaches of the reporting duty had yet been referred to the BZSt unit responsible for fines.
This is on the page because it argues against our own pitch. Two things belong with it. First, it was a snapshot: operator reports had only existed since spring 2024, so the figure covers roughly ten months. Second, CARF differs in one way that matters for enforcement: registration for crypto-asset operators has been open at the BZSt since 13.05.2026. Anyone who registers is known by name, whereas under DAC7 the administration first had to find the obligated entities.
So our argument is not the penalty. It is that the duty repeats every year, that data about your customers goes to the tax administration, and that the work in front of the filing has to happen either way: collecting self-certifications, resolving residencies, carrying corrections through. Selling a deadline as a cliff is selling fear. We are selling the workflow.
Two honest notes
First: this product is under construction. We are developing it with a deliberately small Founding Circle, on the same deterministic engine that powers our stablecoin bookkeeping: versioned rules, documented sources, a hash-chained audit trail. Second: the BZSt has announced but not yet published details of the filing procedure; the administration may provide its own aids. What no portal will ever take off your hands is the due diligence, the self-certifications and the corrections cycle before the filing - that is where the workload sits, and that is where we start.
A few lines are enough: who you are, roughly how many reportable users, how you handle it today. We reply personally.
Information as of September 2026; legal basis: Germany's crypto tax transparency act (KStTG) and the BMF letter of 14.01.2026 on the CARF reporting format. The DAC7 enforcement figures come from the federal government's answer, Bundestag Drucksache 20/14937 of 10.02.2025. This page describes a product, not legal or tax advice; whether and how your firm must report is a question for your advisors.