Berlin 6.0
The Berlin 6.0 DARTE session took place on June 15th, 2026, in collaboration with the European Commission, Bitvavo, and N26. This edition departed from the usual structure of DARTE sessions, inviting participants to question the FATF framework itself rather than confining the discussion to how the industry should operate within it. The roundtable examined the current revision of the FATF Recommendations and what a more proportionate, effective, and rights-respecting alternative might look like.
Three themes anchored the discussion. Nadine Kari (N26) opened with an examination of Recommendations 10, 15, and 20 on customer due diligence, new technologies, and suspicious transaction reporting, exploring how data fragmentation, AI governance, and the absence of FIU feedback shape the operational reality of the current regime. Zornitsa Daskalova (Zodia) followed with a proposal to repurpose Recommendation 16 from the bulk transmission of identity data into participation in qualifying intelligence-sharing networks anchored in rule-of-law safeguards. Dr. Agata Ferreira (Status) closed the technical sessions with a proposal to revise Recommendation 33 and introduce two new Recommendations, 41 on independent evidence-based evaluation and 42 on fundamental rights safeguards, addressing the absence of any mechanism to evaluate whether the regime achieves what it sets out to achieve.
A theme that ran through all three discussions, and one that BlackVogel has been raising across global forums in recent weeks, is the distinction between measuring how effectively institutions comply with the standards and asking whether the standards themselves achieve what they were built to do.
1 Why Traditional Accounting Systems Fail to Scale for Web3 Transaction Compliance
The first session examined why traditional accounting and ERP systems cannot efficiently process Web3 transactions on a transaction-by-transaction basis, and why this has become a material barrier to institutional adoption of digital assets. Participants discussed how short block times, smart contracts, and DeFi processes can generate between 50,000 and 200,000 accounting lines per year for a single active user, the case for a dedicated upstream system that aggregates and translates blockchain transactions into traditional accounting logic while preserving a revision-safe audit trail, and the disproportionate burden the current approach places on smaller businesses. The session also explored the deeper challenge of normalizing diverse DeFi strategies for correct tax treatment, the absence of international accounting standards for crypto-assets, and the role the industry could play in shaping them.
Call to Action
Adopt a standardized upstream aggregation layer at EU level that aggregates Web3 transactions into transaction-type-specific summary bookings while retaining full transaction-level data and a revision-safe audit trail, keeping compliant bookkeeping viable for businesses of all sizes.
Build a shared, jurisdiction-aware transaction mapping library that maps standard Web3 transaction types to their accounting and tax classifications, updated continuously as new DeFi strategies emerge.
Engage the IFRS Foundation on crypto-asset accounting standards, prioritizing consistent treatment of stablecoins and EMTs across IFRS categories and a continuity principle protecting justified, good-faith classifications from retroactive challenge.
2 Information Asymmetries between Users and Tax Authorities in DAC8 Reporting
The second session addressed the structural information asymmetry under DAC8 reporting: the imbalance between the extensive crypto-transaction data transmitted automatically to tax authorities and the limited transparency available to affected users. Participants confirmed the asymmetry, drawing on comparable experience under DAC2/CRS where authorities issued assessments based on gross proceeds rather than realized gains, and stressed that DAC8 is a transparency framework, not a taxation norm. While the group did not reach consensus on proactively distributing full reports to all users, it agreed clearly that users must be able to obtain meaningful transparency where needed, through transaction-level drill-down on request and generic explanatory reports describing how figures are aggregated, valued, and classified.
Call to Action
Develop generic DAC8 explanatory reports across CASPs, explaining the aggregation methodologies, valuation logic, classification approaches, and reporting assumptions applied, drawing on shared industry best practices.
Ensure transaction-level drill-down capabilities on request, allowing users to reconstruct how aggregated DAC8 values were built from individual transactions, valuations, wallet classifications, and transfers.
Promote operational transparency beyond GDPR rights, ensuring users receive understandable and practically useful information and that DAC8’s character as a transparency framework, not a taxation norm, is clearly communicated to tax authorities.
3 Extensive Reporting on Crypto Transactions and the Challenge of Correct Classification of Digital Assets
The third session addressed two interlocking challenges in operationalizing DAC8/CARF reporting: the complexity of fiat conversion and valuation across reportable transactions, and the difficulty of correctly classifying digital assets to determine which reporting regime applies. Participants discussed the lack of clarity around acceptable conversion rates, the consequential and jurisdiction-specific question of whether an asset is reportable under CRS or CARF, and the risk of authorities issuing assessments based on gross amounts rather than realized gains. The discussion also examined the structural underrepresentation of crypto-native firms in international standard-setting, and concluded candidly that, absent a globally unified legal and tax framework, there is no complete solution to the classification challenge, with the realistic path lying in pragmatic simplifications, continuity principles, and stronger industry coordination.
Call to Action
Permit standardized conversion and valuation simplifications, allowing CASPs to rely on defined, publicly available conversion rates or daily average rates to reduce operational burden and divergent interpretation.
Pursue pragmatic classification support while acknowledging its limits, recognizing that no shared resource can bind regulators or override jurisdiction-specific tax treatment, paired with a continuity principle protecting good-faith classifications from retroactive challenge.
Clarify the evidentiary status of reports and ensure recognition of corrections, so that reported figures are understood to indicate crypto activity rather than taxable gain, and correction reports are recognized across borders.
Strengthen crypto-native representation in international standard-setting, ensuring OECD and other working groups reflect the operational realities of crypto-native providers and not only the priorities of traditional financial institutions.
STOCKHOLM PARTNERS
For more information about the MiCAR Roundtable Expert Series:
mariana@delaroche.consulting / nina.siedler@siedler.legal