Advising CASPs on CARF and DAC8: a readiness guide for firms
Advising a CASP toward CARF and DAC8 readiness? The assessment framework, the common gaps, and how to hand clients a working pipeline, not a slide deck.
Published7 min read
If your firm advises crypto-asset service providers, CARF and DAC8 readiness is turning into steady work. It's also unusually clear-cut, since the obligation checks against a list. This guide sets out the framework we'd use to move a CASP from "we know it's coming" to ready to file, and flags where the gaps tend to open up.
Start with nexus and scope
The first question is a legal one, not a technical one. Where does the client actually have to file, and who counts as reportable? Nexus follows where the client is based, so most report in a single country, and that answer frames the whole engagement. Ground the client in nexus under CARF before you touch anything else.
Check the due diligence
The most common gap sits at onboarding, not at the report itself. Are self-certifications collected, reasonableness-checked, and tax-ID validated? Are controlling persons captured for company accounts? Is there a 60-day process for the users who won't certify? The self-certification workflow is the list to run against.
Map the formats and the dates
Then come the mechanics: which authorities, which national formats, which dates. A client filing in the EU and in a national market like Sweden needs the DAC8 version and the KU94 format, not the OECD one alone, and the deadlines by country tell you what the calendar looks like.
Hand over a working system, not a slide deck
Readiness advice is worth more when it ends in a running system instead of a report. Once the assessment is done, our CARF and DAC8 platform is what we point clients to: the due diligence, the formats, and the validation, all in one place. Firms that place clients this way can list in our CPA and advisor directory, or book a demo to see what you'd be handing over.
A quick readiness checklist
The short version, one you can run against any client:
- Nexus settled: the one country of reporting, worked out from where the client is based.
- Self-certifications collected, reasonableness-checked, and tax-ID-validated, with controlling persons captured for companies.
- A 60-day cure-and-block process for users who won't certify.
- The right output format per authority, any national one included, checked before you submit.
- Dates mapped, and the 2026 data already clean enough to file from in 2027.
About the author
FAQs
- How do you assess a CASP's CARF readiness?
Begin with nexus and scope: where they file, and who's reportable. From there, work through onboarding due diligence, the self-certification, reasonableness check, tax-ID validation, controlling persons, and the 60-day process. Last, map the national formats and dates they're up against.
- Where do CASPs most often fall short on CARF?
At onboarding, well before the report. The usual gaps: self-certifications and tax IDs that are missing or never checked, no controlling-person capture for company accounts, and no cure-and-block process.
- How can an advisory firm hand clients a CARF solution?
Pair the readiness check with a platform that runs the due diligence, the formats, and the validation, so the engagement ends in a working system rather than a memo. Firms can also list in the Kryptos CPA and advisor directory.
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