From 1 January 2026, crypto exchanges and brokers in the EU and the UK collect identity and transaction data on their users for tax authorities, and the first reports cover all of calendar 2026. UK platforms report by 31 May 2027, EU tax authorities exchange the data by 30 September 2027, and US brokers file Form 1099-DA under a separate regime.
What changed on 1 January 2026
The OECD's Crypto-Asset Reporting Framework (CARF) went live in its first wave of jurisdictions. It does for crypto what the Common Reporting Standard did for bank accounts: the platform tells its tax authority who the customer is and what they did, and that authority passes the data to the customer's country of residence.
Inside the EU the framework arrives as DAC8, which amends Directive 2011/16/EU on administrative cooperation. Article 2 of the directive, adopted on 17 October 2023, states that Member States "shall apply those provisions from 1 January 2026". It is enacted and in force. The United Kingdom applies the same standard through the Reporting Cryptoasset Service Providers (Due Diligence and Reporting Requirements) Regulations 2025, with an addition the EU does not have: UK platforms also report UK resident users to HMRC. The effect: activity on a foreign platform now reaches the tax authority of the country of residence whether or not it is declared.
Who has to report
Platforms report, not individuals. HMRC's guidance defines a reporting cryptoasset service provider as a business that "transacts cryptoassets on behalf of users" or "provides a means for users to transact cryptoassets", and names exchanges, brokers and dealers as examples. Where several countries have a claim, tax residence comes first, so a platform resident in France and incorporated in the UK reports only in France.
UK platforms collect details on every user but report only those resident in the UK or another CARF jurisdiction. Moving coins to self-custody does not hide them: under DAC8 a platform reports the aggregate value of transfers it makes to ledger addresses not known to belong to another provider or financial institution.
What a platform reports about you
Section II of Annex VI to DAC8 sets out the contents. For each reportable user, the platform reports the name, address, Member State of residence, tax identification number and, for an individual, date and place of birth. For each type of crypto-asset, it then reports aggregated figures for the year:
- Acquisitions and disposals against fiat currency · aggregate amount paid or received, units and number of transactions
- Exchanges between crypto-assets · aggregate fair market value, units and number of transactions on each side
- Retail payments for goods or services above USD 50,000 · aggregate fair market value, units and number of transactions
- Transfers to unknown ledger addresses · aggregate fair market value and units
The report carries proceeds and values, not a computed gain. The authority compares the raw figures with the return.
When the first reports are due
The first reports all cover calendar 2026. The deadlines differ by regime:
- EU (DAC8) · data from 1 January 2026 · platform filing date set by each Member State · exchange between authorities by 30 September 2027 for 2026
- UK (CARF Regulations 2025) · data from 1 January 2026 · register by 31 January 2027 · first report 1 January to 31 May 2027, then by 31 May each year
- United States (Form 1099-DA) · sales effected after 2025 · gross proceeds for all digital assets, basis for covered securities · CARF exchanges by 2029
Beyond these, the OECD list governs exchanges with other partners. Switzerland, Singapore, Hong Kong, the UAE, Canada and Australia are in the 2028 group. Georgia, India, El Salvador and Viet Nam are identified as relevant but uncommitted as of 14 September 2026. Cyprus sits in the 2028 group for CARF, but DAC8 binds it from 1 January 2026 like every Member State.
What happens if a user does not cooperate
The EU rule is blunt. Annex VI to DAC8 provides that where a user does not supply the required information "after two reminders following the initial request", and not before 60 days have passed, the platform "shall prevent the Crypto-Asset User from performing Reportable Transactions". The account is blocked, not merely flagged.
The UK relies on penalties. HMRC's manual, at IEIM8000620, lists up to £300 for a user who deliberately or carelessly fails to provide a valid self-certificate. Platforms face up to £300 per user for failing to collect one, and up to £5,000 for a late report plus up to £600 a day while it continues.
Heed's reading: from 2026, crypto held on a platform is reported the way foreign bank accounts are under the Common Reporting Standard. The exposure has moved from not being found to filing figures that do not match the platform's report.
How the US rules differ
The United States has not yet joined the first CARF wave. Its brokers report through Form 1099-DA, and the IRS's 2026 Instructions for Form 1099-DA set out the scope: mandatory gross proceeds reporting for all digital assets, mandatory basis reporting for covered securities, and voluntary basis reporting for noncovered securities. A covered security is broadly a digital asset acquired after 2025 in an account the broker holds in custody. US persons abroad face this alongside FBAR and Form 8938 reporting.
Two de minimis rules apply. A broker using the optional method for qualifying stablecoins skips designated sales if the customer's aggregate gross proceeds from them do not exceed $10,000 for the year. A payment processor skips payment sales of $600 or less for the year.
Illustration: a customer sells two qualifying stablecoins through one broker using the optional method, $6,200 of one and $4,100 of the other. Aggregate gross proceeds: $6,200 + $4,100 = $10,300. That exceeds $10,000, so the broker reports both, each on its own Form 1099-DA. Had the second sale been $3,700, the total would be $9,900 and neither would be reported on the form, though the gain stays taxable.
Heed monitors international tax law changes across every jurisdiction we track and sends personalised alerts before they affect your situation. Our crypto tax overview and the UK and US country guides cover how gains are taxed once they are reported.