DAC8 and AADE: what crypto data exchanges report and when

DAC8 covers specific crypto activity from January 1, 2026, with the first reports in 2027 and an exchange of information between European tax authorities by September 30, 2027. Greece has transposed the rules, but DAC8 does not impose a tax on its own: the amounts passed on to AADE (Greece’s Independent Authority for Public Revenue) are not the same as net profits.

Where do DAC8 and AADE stand today?

The reporting obligation applies in Greece, while the taxation of each type of income needs to be examined separately. What follows is based on the information available as of November 1, 2026.

The European and Greek provisions

Directive (EU) 2023/2226 of October 17, 2023, known as DAC8, amends Directive 2011/16/EU on administrative cooperation in the field of taxation. The reporting and due diligence rules generally apply from January 1, 2026.

Law 5301/2026, Government Gazette (FEK) A 74/May 15, 2026, transposed it in Greece. Article 8 added Article 9AD to Law 4170/2013, and Article 22 added Annex VI with the detailed obligations. Articles 28–29 cover audits of and penalties for providers. Article 127(2) sets Part A to apply from January 1, 2026, while paragraph 3 separately governs the start of Part B and Article 28.

AADE circular O.3023/May 27, 2026 communicates the law; it does not prove that all the technical details of filing have been set. Implementing Regulation (EU) 2025/2263 of November 12, 2025 concerns the standard forms and electronic formats for exchanges between authorities, not automatically an exchange’s domestic filing.

Why DAC8, MiCA and CARF are not the same

MiCA, Regulation (EU) 2023/1114, regulates the market and service providers, not Greek income tax rates. Its general provisions apply from December 30, 2024, with certain stablecoin rules applying earlier, and Greek measures are included in Law 5193/2025, Government Gazette (FEK) A 56/April 11, 2025.

Law 5273/2026, Government Gazette (FEK) A 13/January 30, 2026, ratified the multilateral agreement on the OECD’s Crypto-Asset Reporting Framework (CARF), which was communicated with circular O.3005/February 4, 2026. It provides a route for exchanging information with participating non-European jurisdictions, subject to the relevant conditions. Separate from these are the transfer-information (“travel rule”) requirements of Regulation 2023/1113 and the Anti-Money Laundering Regulation 2024/1624, which generally applies from July 10, 2027.

Who does DAC8 apply to and which crypto does it cover?

DAC8 applies to individuals and entities that use reporting providers, and the key criterion is tax residence, not nationality. For certain entities, the reportable persons who control them are also reported.

It is not limited to Greek exchanges. It also covers cross-border providers, and certain operators without a MiCA license that serve users in the EU must register in a member state. There are rules to avoid certain duplicate reports.

It includes many decentralized crypto-assets, stablecoins, e-money tokens and some NFTs. But not every NFT automatically. Likewise, a transaction without a reporting intermediary does not trigger a DAC8 report just because it was recorded on a blockchain. A transfer from an exchange to a self-hosted wallet, on the other hand, may be reported.

What data do exchanges send?

Reports are made annually, as a rule per user, per crypto-asset and per transaction category, under Annex VI, Section II, of Law 4170/2013.

Identification details

These include the full name or company name, address, countries of tax residence and tax identification numbers, such as the Greek tax ID (AFM). For individuals, the date of birth is reported, while the place of birth is subject to a specific exemption. For reportable controlling persons, their role is also included. Details of the provider and its required identification numbers are reported as well.

Amounts and transaction categories

Amounts are expressed in a specified fiat currency, with consistent valuation at the time of the transaction where required. There is no general requirement here to send every wallet address or transaction hash.

The threshold of more than $50,000, or the equivalent, applies to the specific category of retail payments for goods or services. It is not a general tax-free allowance, nor a reporting threshold for purchases and sales.

When does the data reach AADE?

The first reporting year is 2026, but provider filing and the exchange between authorities follow different timelines.

1. January 1, 2026 The first reporting period begins: providers record 2026 transactions.
2. By January 1, 2027 Pre-existing customers provide a self-certification of tax residence to their provider.
3. During 2027 Providers file their first annual data. The exact Greek deadline, the platform and the technical specifications still need official confirmation.
4. By September 30, 2027 European tax authorities exchange the 2026 information with each other.

A reporting provider in another member state may report there first, and the competent authority can then pass the data of a Greek tax resident on to AADE. So a foreign exchange does not mean no reporting.

How are the amounts and the tax calculated?

A DAC8 report is not a statement of profits. Consider a user who, in 2026, buys 0.5 BTC for €20,000, sells 0.2 BTC for €12,000 and transfers 0.1 BTC, worth €6,500, in the relevant external-address category.

Acquisitions, sales and transfers are reported separately. The €12,000 is not automatically profit, and the €6,500 is not automatically income. You need the acquisition cost and the correct tax classification.

Individuals and businesses in 2026

There is no established blanket 15% tax on crypto. Articles 42–43 of Law 4172/2013 cover specific capital gains. Dispute Resolution Directorate (DED) decision 3407/2026 rejected the application of Articles 42 and 42A to the crypto income under review, without being a court ruling for every case. Neither “it’s all tax-free” nor “it’s all at 15%” is a safe conclusion.

For companies, the general tax rate is 22% on taxable profits, not turnover: a profit of €10,000 gives an initial tax of €2,200, before other adjustments. For sole-proprietor business activity, the 2026 scale with no dependent children includes 9% up to €10,000, then 20%, 26% and 34% for each subsequent €10,000, 39% from €40,000 to €60,000, and a further statutory bracket above that. Age and children can change the result.

On VAT, the CJEU ruling C-264/14, Hedqvist, of October 22, 2015 concerns the exemption of the specific exchange of fiat currency for Bitcoin, not every crypto service.

What the October bill proposes

The draft that was put to public consultation on October 7, 2026 and submitted to Parliament on October 28, 2026 is not documented as passed as of November 1, 2026. The proposed Articles 44–50, with a new Article 42B of the Income Tax Code (KFE), provide for key changes from January 1, 2027, if passed as drafted:

• A 10% tax on eligible capital gains of individuals and an exemption for annual net profit of up to €500. At €501, the entire profit is taxed: €50.10.
• No tax on crypto-to-crypto swaps, even though these may be reported under DAC8, and different treatment for disposals against money or goods and services.
• A five-year loss carryforward under conditions, including an annual loss cap, and 15% as interest for eligible staking, lending and liquidity-providing yields.
• Inclusion of crypto purchases in acquisition expenses, and an optional disclosure of eligible past income within 12 months, payment within 60 days and, under conditions, exemption from penalties. A limit is set on how far the returned acquisition cost can cover deemed-income presumptions (“tekmiria”).

What do you declare and where?

The exchange’s report does not replace your tax return. Individuals file Form E1, sole-proprietor business activity may require Form E3, and companies file the relevant legal entity return.

1. Gather purchases, sales, fees, transfers and valuations from all your providers.
2. Separate sales, swaps, movements of your own funds and yields.
3. Review the classification and codes with an accountant. Codes 865–866 in the 2025 income instructions refer to specific foreign securities, not a universal crypto code. A specific code for 2026 has not been confirmed.
4. Meet the deadline: for 2026 income, the usual window is March 15 to July 15, 2027, subject to any extension or special rule.

Points to note

• Keep proof of acquisition costs, fees, transfers and the original source of the money. Annual totals are not always enough.
• Providers request and check self-certifications, tax IDs (AFM) and proof of residence.
• 2026 being the first DAC8 year does not shield earlier years from audit. Other information-gathering powers remain available.
• The fines in Article 29 of Law 5301/2026, which adds paragraphs 10–11 to Article 59 of Law 5104/2024, apply to providers: €100 per transaction for late filing, €300 for omission or inaccuracy, €1,000 for a specific failure to respond, €2,500 for the relevant non-compliance and €5,000 for failing to provide data after an audit. The overall cap is €500,000 per audit, and it is not an automatic fine on customers.

Our view

We think the real preparation is documentation, not hunting for a supposedly “safe” exchange. This article is not tax advice: you need an accountant, and a check of the final provisions and of AADE’s pending decisions.