DAC8 in Italy: The Roll-Out Timeline No Italian CASP Has Mapped

Italy transposed DAC8 with Decreto Legislativo 194/2025, signed on 10 December 2025 and published in the Gazzetta Ufficiale on 22 December — nine days before the obligations went live. Most Italian CASPs filed it under "first report due mid-2027, deal with it later." That mental model is wrong in a specific and expensive way: the deadline is in 2027, but the obligations started running on 1 January 2026. The data you will have to report next year is the data you are collecting — or failing to collect — right now.

Here is the actual timeline, decree in hand: what is already in force, what the Agenzia delle Entrate still owes you, and which dates bite before the one everyone has in their calendar.

What D.Lgs. 194/2025 Actually Establishes

The decree transposes Directive (EU) 2023/2226 — DAC8 — and deliberately tracks the OECD's CARF standard without Italian gold-plating: no additional exemptions, no extended scope, no national deviations. The structural points:

• Who reports — MiCA-authorised CASPs operating in Italy, plus "crypto-asset operators" outside the MiCA perimeter that meet the criteria. If you have Italian users and execute relevant transactions for them, assume you are in scope.
• Registration with the Agenzia delle Entrate — Art. 15 of the decree introduces a registration obligation for reporting entities, with coordinated notification flows involving Banca d'Italia and CONSOB. Registration procedures arrive via implementing measures — see below.
• Annual communication — relevant transactions (acquisitions, disposals, exchanges, retail payments, transfers — including transfers to unhosted wallets) reported per user, per asset type, with amounts and unit counts, by 30 June of the year following the reference period.
• Automatic exchange — the AdE then exchanges the data with the other EU tax administrations under the DAC framework; data on Italian residents using foreign CASPs flows back to the AdE the same way.

The Timeline, in the Order It Actually Bites

Read this top to bottom as "what should already be true" turning into "what is about to be due":

1. 1 January 2026 — collection and due diligence went live. Self-certifications of tax residence, TINs, controlling-person identification for entity accounts: the CARF due-diligence machinery applies to users transacting from this date. This is the deadline that already passed.
2. Mid-2026 — the AdE's implementing measures are still the missing piece. The decree delegates electronic formats, transmission channels, currency-conversion rules, and self-certification handling to technical provisions of the Agenzia delle Entrate. Watching for that provvedimento is not optional: registration windows and format specifications will land there, likely with less lead time than anyone would like.
3. Registration — once the procedures are defined, reporting entities register with the AdE. An entity that waits for the provvedimento to start preparing has chosen to compress its own build time.
4. 30 June 2027 — first communication, covering the full 2026 reference year.
5. Autumn 2027 — first automatic exchange between the AdE and the other EU administrations, and the first inbound data on Italian residents holding crypto abroad.
6. 2027–2028 — the cross-checking begins. Transaction-level CASP data meets quadro RW and the capital-gains declarations — in the same years the 2026 budget rules (26% rising to 33%, franchigia gone) take full effect. The enforcement wave DAC8 was designed to enable starts here.

What Goes in the Report

Per reportable user, the communication carries identity and tax residence (with TIN), controlling persons for entity accounts, and the year's relevant transactions broken down by crypto-asset type: acquisitions and disposals (against fiat and against other crypto-assets), retail payment transactions, and transfers — with unhosted-wallet transfers identified as such. Amounts, unit counts, and the fiat valuation per the conversion rules the AdE's technical specs will fix. If your data model cannot already produce that breakdown for 2026 year-to-date, that is the gap to close now — not in the spring of 2027.

The Enforcement Backdrop

The decree attaches administrative penalties of €1,500 to €15,000 per violation for failures in the reporting and due-diligence obligations — per violation, not per year, which is how incomplete user files compound. But the sharper risk for a CASP is not the fine; it is being the institution whose sloppy first report triggers accertamenti against its own customers on transactions they did declare — or whose missing data makes it the outlier in the AdE's first cross-jurisdiction dataset. In the first year of a new automatic-exchange regime, the reporting entities that stand out are the ones that get the follow-up questions.

How BA helps. The raw material of a DAC8 communication is a complete, per-user, per-asset transaction history — which is an extraction problem before it is a reporting problem. BA's tax tooling reconstructs customer transaction histories across chains in structured form, the layer underneath the CARF-format pipeline. The operational walkthrough — from raw on-chain data to a CARF-ready extract — is the subject of the next piece in our Tools for Compliance series. For the EU-level framework, see DAC8 Explained: EU Crypto Tax Reporting for Businesses.

Coming up in the "Tools for Compliance" series: #5 — the DAC8 Reporting Workflow: extracting customer transactions in CARF-ready format, field by field, before the AdE's technical specs make it urgent.