EU and Switzerland Diverge on Crypto Data-Sharing Implementation Timelines

The European Union has introduced sweeping crypto data-sharing rules under the expanded Directive on Administrative Cooperation (DAC8), set to take effect on January 1, 2026. These regulations, published as Implementing Regulation (EU) 2025/2263, mandate standardized reporting of customer holdings and transactions by crypto-asset service providers, including exchanges and wallet providers. Key elements include a unified digital format, a Crypto-Asset Operator register with 10-digit identification numbers, and data retention requirements for up to 12 months after deletion.

This framework aligns with the Transfer of Funds Regulation (TFR), effective December 30, 2024, which extends the 'travel rule' to crypto transfers above €1,000 and requires identification for self-hosted wallet interactions. The rules complement MiCA and anti-money laundering measures, with the European Securities and Markets Authority (ESMA) potentially gaining direct oversight of major cross-border exchanges. However, resistance from countries like Luxembourg, Malta, and Ireland highlights concerns over centralization and compliance costs.

In contrast, Switzerland has delayed its automatic exchange of crypto tax data with foreign authorities until at least 2027, despite having the legal framework ready from January 1, 2026. The delay stems from unresolved partner agreements under the OECD's Crypto-Asset Reporting Framework (CARF). Switzerland plans to exchange data with 74 jurisdictions, including EU member states and G20 countries like Japan and Australia, but excludes the US, China, and Saudi Arabia due to alignment issues.

The divergence underscores global challenges in regulatory harmonization, with privacy debates and cross-border cooperation hurdles highlighted by entities like the Financial Stability Board.