Partner and Head of Web3 & Disruptive Technology, Zoe Wyatt, and Crypto Tax & Accounting Technical Director, Dion Seymour, discuss the implications of the OECD’s extension of the CRS, in Bloomberg Tax.
As digital assets continue to challenge traditional financial systems, the OECD has launched a dual-pronged approach to modernize tax transparency that represents a seismic shift in the global tax landscape. The OECD has extended the common reporting standard, or CRS, to cover certain digital financial products, and introduced the crypto-asset reporting framework, or CARF, focused exclusively on cryptoasset transactions. Cryptoasset platforms and fintechs must now be prepared to operate under the same scrutiny as traditional financial institutions.
Standalone Regime
An entity’s obligation under CARF depends on whether it qualifies as an RCASP. That determination is the first and most critical step. If crypto platforms, brokers, and wallet providers determine that they are RCASPs, several action points follow:
- Assess data collection gaps. Do current onboarding flows collect tax residence and tax identification numbers? Are transfers between hosted and self-hosted wallets tracked and attributed to users? Can fiat equivalent values be reliably calculated and timestamped?
- Choose a technology path. Build an internal compliance engine that aligns with CARF and reporting deadlines or buy an external solution (RegTech or reporting-as-a-service) to handle data processing and submission.
- Review governance and legal exposure. This means ensuring clear internal responsibilities for tax reporting, documenting reporting logic and user classification decisions,; and monitoring developments in each jurisdiction where users are based.
- Identify reporting jurisdiction. If an RCASP has a nexus with only one CARF jurisdiction, it must report all relevant information to that single jurisdiction’s tax authority. If the RCASP has a nexus with multiple jurisdictions, it may choose any one of them for its CARF reporting obligations, but only if that jurisdiction is committed to CARF, and the RCASP notifies all relevant tax authorities of its chosen reporting jurisdiction.
Phased Global Adoption
The updated CRS and CARF are both scheduled to begin in most early-adopting jurisdictions on Jan. 1, 2026, with first reports due by mid-2027. Others may opt for a Jan. 1, 2027 start, providing an additional year for legislative and technical preparation.
Importantly, these aren’t self-executing systems. Each jurisdiction must implement enabling domestic legislation and define its own penalties and enforcement rules.
The EU is transposing both frameworks into the directive on administrative cooperation DAC8, (for cryptoassets) and DAC2 (for traditional finance) with a 2026 start date. Additionally, the UK has committed to both CARF and the CRS amendments from 2026. Many offshore jurisdictions have yet to publish draft legislation.
This patchwork implementation creates uncertainty for multinational crypto platforms, particularly where users and services span jurisdictions with differing start dates.
User Guides
To support implementation, the Organization for Economic Cooperation and Development has published user guides for the CRS and CARF. These technical guides specify the electronic reporting formats (XML schemas) that tax authorities and reporting entities must follow when exchanging information.
The CARF guide focuses on aggregate level data, including asset type, quantity, transfer values, and wallet addresses. The CRS guide revisions focus on enhanced account metadata, accommodating digital product classifications and new due diligence fields.
Both guides include validation rules and are highly prescriptive, so reporting systems must align precisely to avoid rejection by receiving authorities.
Going Forward
While implementation will vary, the direction of travel is clear. Tax authorities worldwide are building a net wide enough to include digital assets, directly via CARF and indirectly via the CRS.
The prudent course of action for businesses is early investment in compliance infrastructure, robust legal review, and proactive engagement with tax authorities.
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