How EU DAC8 and UK CARF Crypto Rules Compare to Swiss Privacy Law

EU crypto reporting rules are entering a new phase with the introduction of DAC8 in the European Union and the OECD’s Crypto-Asset Reporting Framework (CARF), fundamentally changing how crypto activity is reported across borders. In parallel, the United Kingdom is implementing its own crypto reporting framework aligned with the OECD Crypto-Asset Reporting Framework, commonly referred to as CARF.

While both frameworks aim to improve transparency, they also introduce broader data collection and, as a result, increased cross-border information exchange. At the same time, however, Switzerland continues to regulate crypto through a different legal and regulatory philosophy, one that combines strict compliance with strong privacy protections.

This article explains what DAC8 and CARF are, how they affect crypto users in the EU and UK, and why Switzerland applies a structurally different approach to regulation and data protection.

EU Crypto Reporting Rules Explained: DAC8

In practice, DAC8 is the latest extension of the EU Directive on Administrative Cooperation. It expands mandatory tax reporting obligations to include crypto assets and crypto service providers operating in or serving the European Union.

Under DAC8, reporting obligations include:
– crypto asset transactions
– user identity and residency data
– wallet and account identifiers
– cross-border information exchange between EU tax authorities

As a result, the framework enables automatic sharing of reported data across EU member states. Therefore, the objective is to increase transparency and reduce tax evasion involving digital assets. Under the new EU crypto reporting rules, crypto service providers must collect, verify, and report user transaction data to tax authorities.

UK Crypto Reporting Rules Explained: CARF

At a global level, CARF stands for the OECD Crypto-Asset Reporting Framework. It is a global standard designed to align crypto tax reporting across jurisdictions.

In contrast, the European Union implements CARF through DAC8. Meanwhile, the United Kingdom applies CARF through its own domestic legislation rather than EU directives.

In practice, the UK framework includes:
– reporting by crypto asset service providers
– collection of user and transaction data
– reporting to HMRC
– international information exchange under OECD agreements

However, although DAC8 does not apply in the UK, the outcome for users is similar. Crypto activity becomes more visible to tax authorities, with broader data sharing than in earlier regulatory models.

How DAC8 and CARF Affect Crypto Users

In practical terms, for users in the EU and UK, DAC8 and CARF significantly expand reporting scope.

This typically results in:
– more extensive personal data collection
– transaction-level reporting
– cross-border data propagation
– reduced separation between platforms and authorities

Importantly, these frameworks do not distinguish between speculative trading and practical payment use cases. All qualifying activity falls under the same reporting structure.

Consequently, for users, this raises questions around proportionality, data minimization, and long-term data storage.

Switzerland Regulates Crypto Differently

By comparison, Switzerland regulates crypto under a different legal foundation.

Instead of automatic mass data exchange, Swiss regulation emphasizes:
– strict onboarding and AML enforcement
– purpose-limited data collection
– high thresholds for data disclosure
– judicial oversight for information access

Swiss Crypto service providers offering crypto to direct fiat settlements (to any bank account), must comply with AML law, perform KYC, and monitor transactions. However, user data is not automatically shared across borders or pooled into multinational reporting systems.

Swiss Privacy Law and Financial Data

At the same time, Swiss data protection law places strong limits on how financial data may be used and disclosed.

Key principles include:
– data access only on legal basis
– court-ordered disclosure rather than automatic exchange
– strict limits on secondary data use
– controlled cross-border data transfers

As a result, compliance exists, but data does not circulate by default.

Compliance Is Not Optional in Switzerland

To be clear, Switzerland is not a lightly regulated jurisdiction.

Crypto platforms must:
– register with a recognized self-regulatory organization such as So-Fit or VQF
– implement full AML frameworks
– verify users and transactions
– cooperate with authorities when legally required

Instead, the distinction lies in how data is handled after compliance, not whether compliance exists.

Why This Difference Matters

Ultimately, for users and businesses, regulatory structure shapes privacy outcomes.

The Swiss model results in:
– less automatic data sharing
– clearer legal boundaries around access
– more predictable compliance exposure
– lower risk of multi-jurisdictional reinterpretation

Therefore, this is particularly relevant for users who operate internationally and value legal certainty.

Switzerland Is Not Opposed to Transparency

Nevertheless, Switzerland participates in international cooperation and complies with global standards.

The key difference, however, is proportionality.

Where DAC8 and CARF prioritize automatic information exchange, Switzerland prioritizes legal precision, data minimization, and controlled disclosure while maintaining full compliance.

What This Means for EU and UK Users

EU and UK users now operate in an environment where crypto activity is increasingly integrated into multinational reporting frameworks.

As a result, for users who prefer:
– defined legal thresholds
– strong data protection
– compliance without continuous data export

Switzerland offers a structurally different regulatory environment.

Importantly, this is not about avoiding rules. It is about how rules are applied.

DAC8 and CARF represent a significant shift in crypto regulation across Europe and the United Kingdom. They expand transparency through broad reporting and automatic data exchange.

In contrast, Switzerland demonstrates an alternative model. One where crypto is regulated strictly, but personal and financial data remains protected by strong legal safeguards.

Ultimately, understanding these differences allows users and businesses to make informed decisions about where and how they interact with the crypto economy.

Privacy is not the absence of regulation.
It is the result of careful legal design.

For users and businesses operating internationally, understanding EU crypto reporting rules is now essential when choosing where and how to interact with crypto infrastructure.

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