CARF in Greece: Compliance Guide for CASPs and RFIs

Greek crypto-asset service providers (CASPs) and financial institutions are preparing for a significant update in tax transparency. Effective January 1, 2026, the OECD’s Crypto-Asset Reporting Framework (CARF)—transposed into Greek law via Law 5193/2025 and aligned with EU DAC8—will require detailed reporting on digital-asset transactions, including cryptocurrencies, stablecoins, NFTs, and tokenized assets.

Supervised by the Independent Authority for Public Revenue (AADE) and the Hellenic Capital Market Commission (HCMC), CARF introduces new compliance obligations: enhanced due diligence, accurate transaction tracking, and structured data exchange. Institutions that implement these processes promptly will minimize regulatory risk, streamline reporting, and maintain operational resilience in the evolving digital-asset sector.

This guide provides a structured overview of CARF’s scope, reporting requirements, affected entities, and technical solutions, including automation tools such as TaxDo, to help CASPs and RFIs navigate these regulatory obligations efficiently.

Why CARF Matters for Greece

CARF establishes a standardized framework for the automatic exchange of information on crypto-assets, similar to CRS for traditional finance. Greece, as part of 67 participating jurisdictions, will implement CARF through DAC8 and Law 5193/2025. Reporting begins in 2026, with the first submissions to AADE expected in 2027.

CARF’s objectives include:

• Comprehensive asset coverage: cryptocurrencies, stablecoins, NFTs, and tokenized instruments (excluding closed-loop tokens).
• Detailed transaction reporting: crypto-to-crypto, crypto-to-fiat, transfers, staking rewards, and airdrops.
• Standardized valuation: reporting in fiat-equivalents using ISO 4217 codes.
• Global alignment: consistent with CRS 2.0 updates and FATF AML recommendations.

Greece’s Regulatory Framework

Greece implemented CARF via DAC8 (EU Directive 2023/2226):

• Supervision: AADE manages reporting; HCMC licenses and oversees CASPs under MiCA (2024–2025).
• Due diligence start: January 1, 2026.
• First reporting cycle: submissions for 2026 data expected in 2027.
• Penalties: €10,000–€100,000 per violation under Law 5073/2023, with further sanctions possible for systemic non-compliance.

This ensures alignment with EU standards while strengthening market integrity and consumer protection.

Who Must Comply

CARF applies to a broad range of participants:

• Reporting CASPs: exchanges, custodial wallets, payment platforms.
• Financial institutions with crypto exposure: banks or asset managers providing digital-asset custody or tokenized products.
• DeFi and NFT platforms: hybrid or semi-centralized operators controlling transactions.
• Users and beneficial owners: individuals and entities must provide TINs and residency information.
• Passive entities: UBO verification is required, using corporate records and HCMC guidance.

Reporting Requirements

RCASPs report data to AADE using the OECD CARF XML schema (updated July 2025).

The focus is on ensuring accurate, traceable reporting of cross-border crypto activity.

TaxDo: Technical Infrastructure for CARF Compliance

To manage CARF’s data requirements efficiently, TaxDo provides a regulatory-grade automation platform:

• Global TIN Lookup (GTL): real-time TIN validation across 130+ jurisdictions, generating CARF-ready XML files.
• Global Syntax Verification (GSV): verifies TIN syntax and structure across 195 jurisdictions, meeting CARF “reasonableness” standards.
• Global Identity Intelligence Engine (GIIE): continuous AML, PEP, and sanctions screening across 290+ watchlists, with automated alerts for changes in controlling persons.

TaxDo integrates onboarding, e-signatures, due diligence, remediation, and reporting workflows, reducing errors, strengthening governance, and enabling reliable cross-border compliance.

Practical Compliance Steps

1. Update onboarding and KYC processes to capture TINs, residency, and UBO data.
2. Classify assets accurately: crypto, tokenized instruments, NFTs, stablecoins.
3. Enhance transaction monitoring to align with MiCA and FATF standards.
4. Train staff and audit readiness to maintain compliance.
5. Ensure systems are prepared for reporting large datasets by the 2027 submission deadline.

Global Benchmarks

Conclusion

From 2026, CARF establishes a structured approach to crypto-asset reporting in Greece. CASPs and RFIs must ensure accurate reporting, comprehensive due diligence, and proper identification of users and UBOs. Institutions that implement compliance measures promptly will reduce regulatory risk, maintain operational efficiency, and strengthen trust with regulators and clients.