My crypto history is not complete, what does the first exchange round under DAC8 mean for me?

What do crypto service providers report under DAC8?

Crypto service providers report data about their users and their transactions to the tax authority of their member state, which then exchanges that data with other member states. On this extension of administrative cooperation in tax matters to crypto assets, the European Commission publishes.

For your situation, what is not in it matters most. A report covers the period in which you were a customer at that provider and what was recorded there. Transfers between your own wallets, purchases at a party that has since disappeared and swaps you made years ago outside a provider are not in it.

That crypto holdings are no longer a marginal phenomenon in the euro area is shown by the figures the European Central Bank publishes on this.

What does an incomplete crypto history mean in that situation?

An incomplete crypto history means you have to be able to explain a difference, and that an explanation without underlying entries does not hold up in this kind of conversation. A crypto history is not a file you download somewhere, but a chain you build from several sources that each cover part of the period.

The gaps in a crypto history are in the same three places in almost every file, and it helps to know which of the three applies to you.

• A provider that has disappeared: the platform no longer exists, your account is gone and with it the export function.
• Own wallets without notes: the entries are still there, but nothing has been recorded about the reason and the value at that moment.
• Swaps between coins: every swap is an event with two sides, and it is precisely those sides that are rarely kept together.

In such files Paucitas starts with the entries that do still exist and works back from there. An address you can still point to produces a complete history, even if you have kept nothing yourself.

What if your old provider no longer exists or you can no longer access a wallet?

Then the work is done with what is still visible from the outside: the entries to and from the addresses of that provider, your bank entries from that period and the correspondence you still have. Paucitas uses no automated analysis software, in any role whatsoever. The investigation is done manually on the basis of publicly accessible block explorers. Every transaction and every transaction hash is verified one by one before it is included in a report.

If access is lost, it is investigated whether restoration is technically possible, exclusively on a wallet you lawfully own. Whether that succeeds depends on the data still available: a partial or complete recovery phrase, a file, a note or another lead. We assess your situation without obligation and are honest about what is realistic in your case, without guaranteeing anything. If you do not know whether what you still have is usable, please get in touch.

Complete loss without any lead cannot be restored, and that is then stated as such instead of filled in with an estimate.

What the overview eventually looks like is set out on the question page about crypto assets set out clearly for the declaration. What this means for you as a private individual is set out on the page for private individuals.

How do you build a reconstruction now, before a question is on the table?

You build your crypto history in five steps, and those five steps are also the order in which Paucitas picks up a file. This is the step most often postponed: building a reconstruction before a question comes, not afterwards.

1. List all addresses and accounts you have ever used, including the ones you no longer use.
2. Download the complete transaction history at every existing provider, while it is still possible.
3. Look up the bank entries with which you stepped in and with which you may have stepped out.
4. Note per disappeared provider the period in which you were a customer there and what you remember of the amounts.
5. Name what you can no longer substantiate, separately, so that it is a limitation and not a gap.

Data is supplied digitally or at the office. Per case a delivery list is provided which states what data is needed. Where necessary Paucitas guides the collection and delivery of that data.

Paucitas never asks of its own accord for your recovery phrase or private key. If you need help reading out or restoring your wallet, we guide you through that completely, without us having to see that data ourselves.

• Transactions outside the blockchain, such as cash payments or internal entries within an exchange, are not visible in blockchain data. They are only included if underlying documents are available.
• Paucitas gives no tax or legal advice.
• The report states explicitly to what extent there is still access to the wallet concerned, because that determines what can in fact be established.

That is where the limit of this work lies: Paucitas reconstructs and records what follows from the data, but does not assess how a declaration should be arranged for tax purposes and says nothing about the way an authority weighs a difference.

What does the report produce and how long does it take?

The report produces a chronological overview of your crypto history of your holdings and your entries per period, with the source per element on which it is based and an explicit list of what cannot be established. A report by Paucitas follows a fixed structure: occasion and description of the assignment, question, scope, starting points, data supplied, sources consulted, method in outline, verification and quality assurance, reservations and limitations, findings per element, chronological overview, analysis and coherence, conclusion, statement of independence and appendices. Not every report contains all elements.

An investigation by Paucitas takes, depending on the size of the file and the urgency, between one working day and two weeks. An urgent report can be delivered within one working day and in exceptional cases on the same day. A regular investigation is usually ready within three working days. In files with many transactions, several wallets or missing history the lead time rises to around two weeks. A surcharge applies to urgent assignments.

Paucitas works with a fixed price based on your situation. Sometimes we apply an hourly rate in consultation, but the hours are always fixed in advance, so that you never face surprises. No investigation is started before the costs have been discussed and agreed.

Paucitas usually responds within a few minutes to an hour and in almost all cases the same working day.

Which investigation belongs here you can read under source of funds. What the regulation itself entails and which data belongs in it is set out in the article about DAC8 and crypto reporting.

If you are considering an investigation now, it is wise to start the reconstruction before a question is on the table. A file built up in advance is shorter and cheaper than the same file under time pressure, simply because sources are then still available that have disappeared later.

Send Paucitas an overview of the providers and addresses you can remember, even if it is incomplete. In a first assessment it is named which part of your crypto history can still be reconstructed and which part will appear in the report as a limitation.

Date of last revision: 11 September 2026.