Key Takeaways
- CARF is about transparency, not taxability: CARF is an information-reporting framework focused on financial transparency. Transactions must be reported whether or not they are taxable.
- Global adoption is happening in waves: Implementation is staggered across jurisdictions, with many countries requiring compliance starting 1 January 2026. EU countries and the UK lead wave one, followed by additional regions, with the US currently expected later.
- Scope starts with “effectuating” transactions: If your business facilitates crypto-to-crypto, crypto-to-fiat, or fiat-to-crypto transactions, you may already be in scope — regardless of custody.
- Reporting is annual and aggregated — but data-heavy: CARF requires providers to calculate yearly aggregates per user and per asset type, including total transaction amounts and key gains or losses. This demands robust product mapping and transaction classification.
- Customer due diligence goes beyond KYC: Self-certification of tax residence is mandatory, alongside traditional AML/KYC. Firms must also monitor ongoing changes in customer circumstances.
- Crypto asset definitions are broad:
Most blockchain or DLT-based assets used for payment or investment fall under CARF, including major payment coins and many stablecoins. - Compliance is continuous, not one-time: After onboarding, firms must actively track changes such as address or jurisdiction updates and refresh customer records accordingly.
Speakers:
Max Bernt – Taxbit
Dion Seymour – Andersen
Colby Mangels – Taxbit
