State of the specification
| OECD schema | CARF XML Schema, User Guide as of July 2025 (v1.5). That is the basis our validator checks against. |
| German data specification | Draft. Last seen as a draft, version 0.1. That is not a footnote: while it remains a draft, the binding German record layout can still change. |
| Filing procedure | Announced, not published. The DIP mass-data interface or a portal upload are named; the details are still missing. |
| Monitoring | We check the primary sources for changes automatically (OECD schema, BZSt). If something moves, we change this page and say what moved. |
What has to be done before then
The XML is the last link of a chain that starts much earlier. In the order the work actually occurs in operation:
1. Register with the BZSt. Open to crypto-asset operators since 13.05.2026. Anyone registered is known by name, which changes the enforcement picture compared with DAC7.
2. Collect self-certifications. The real workload, and it runs all year. Residency and tax identification number per user, plus chasing the gaps.
3. Check data quality. Missing TINs are the most common defect. They surface in July 2027 if they do not surface before.
4. Consolidate transaction data. Acquisitions, disposals, transfers per user and crypto-asset, aggregated as prescribed, from the systems where they actually live.
5. Validate the XML structurally. Before filing, not after. An XML that gets rejected is not a filing. Our validator checks it free, in your browser.
6. Plan the corrections cycle. The part nobody talks about. Data changes after filing, and corrections travel as their own message type with their own rules.
Who this applies to
The 86 crypto-asset service providers authorised in Germany under MiCAR, which we list individually in the CASP register, are a large part of the addressees but not all of them. Directive (EU) 2023/2226 expressly also covers crypto-asset operators without a MiCAR authorisation that are resident, incorporated, managed or regularly doing business in a Member State. The register count is therefore a floor.
If this deadline is on a list at your firm: a few lines are enough, roughly how many reportable users and how you handle it today. We reply personally.
Legal basis: Directive (EU) 2023/2226 (DAC8), the German crypto tax transparency act (KStTG), and the OECD Crypto-Asset Reporting Framework XML Schema (July 2025 edition). Fines up to EUR 50,000 per violation under section 18(2) KStTG. The day counts on this page are recomputed daily. This page is not legal or tax advice.