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ReadFor about a decade, banks have reported their foreign customers' accounts to tax authorities under the Common Reporting Standard, or CRS, the system under which more than 100 jurisdictions swap bank account data every year. Crypto sat largely outside that net. From January 1, 2026, that gap starts to close.
Two sets of rules take effect today. The first is the Crypto Asset Reporting Framework, or CARF, a global standard written by the OECD (the Organisation for Economic Cooperation and Development, the Paris based body behind most international tax rules) for the G20 group of major economies. The second is DAC8, an amendment to an EU tax cooperation directive that writes the same standard into EU law.
What exchanges now have to collect
The rules apply to what they call reporting crypto asset service providers: exchanges, brokers, dealers and some wallet providers that buy, sell or swap crypto for customers as a business. From today they must collect, for each user, a name, address, every country of tax residence and the matching tax identification number. Existing customers can expect to be asked to confirm these details in a self certification, a short declaration of where you are tax resident.
The providers then track three kinds of activity through the year: crypto exchanged for ordinary money, crypto exchanged for other crypto, and transfers of crypto. After the year ends, they report the totals for each user and each asset to their own tax authority, which forwards the data to the user's country of tax residence.
The scope covers Bitcoin and other cryptocurrencies, stablecoins, and some non fungible tokens (NFTs, unique digital tokens) used for payment or investment.
Who started today, and who follows
The OECD keeps a list of jurisdictions that have committed to the framework. In its update of December 4, 2025, it named 48 jurisdictions that will make their first exchanges by 2027, which means their exchanges start collecting data now, for the 2026 calendar year. They include the United Kingdom, 26 of the 27 EU member states, Brazil, Chile, Colombia, Japan, Korea, Indonesia, South Africa, New Zealand, Norway, Israel, Liechtenstein, Gibraltar, the Cayman Islands, Jersey, Guernsey and the Isle of Man.
UK providers send their first report to HM Revenue and Customs, the UK tax authority, by May 31, 2027. EU member states must exchange the first year of data by September 30, 2027.
A second group of 27 jurisdictions has committed to first exchanges by 2028, so their collection starts on January 1, 2027. This group includes:
- The United Arab Emirates. The UAE Ministry of Finance confirmed in 2025 that it has signed the agreement under which CARF data is exchanged, with the rules applying in 2027 and the first exchanges in 2028.
- Panama. Listed by the OECD for first exchanges by 2028.
- Others in the same group: Australia, Canada, Switzerland, Singapore, Hong Kong, Türkiye, Mexico, the British Virgin Islands and Cyprus, the one EU member not in the first wave.
The United States is committed to first exchanges by 2029. Five jurisdictions that the OECD considers relevant have not yet committed: Argentina, El Salvador, Georgia, India and Viet Nam, although Argentina has signed a joint statement saying it intends to move swiftly. Paraguay and Uruguay do not appear on the list at all.
What it means if you live in a territorial tax country
Several of the countries our clients move to tax on a territorial basis, meaning they generally tax only income earned inside the country. Paraguay and Panama work this way for individuals, and the UAE has no personal income tax at all. CARF does not change any of that. It is a reporting system, not a tax. It moves information to the country where you are tax resident; what that country does with it depends entirely on its own law.
The practical risks are elsewhere:
- Your declared residency has to be right. The exchange reports you to the country you certify. If your profile still shows an old address in a country that participates, the data may go to your former tax authority, which will see activity it may consider taxable.
- Leaving a country properly matters more than ever. A home, family or time spent in your old country can keep you tax resident there, and it will now see your crypto activity.
- Whether a crypto gain is foreign or local income is not always settled. In territorial systems, the answer can depend on where the exchange, the wallet or the person sits. Get local advice before assuming a gain is outside the net.
- A second passport changes nothing here. Reporting follows tax residence, not citizenship. The one exception is the United States, which taxes its citizens wherever they live.
What to do now
Answer your exchanges' residency requests accurately. Keep a tax residency certificate from your new country, where one is available, and records of what you paid for each asset. Declare your accounts and gains in your real tax home as its rules require.
Banks expect a clean paper trail when crypto proceeds arrive in an account. Through our international banking service we help clients organise source of funds files for crypto proceeds, set up backup accounts in more than one country, and keep their details consistent, so that what each bank and exchange reports matches where they actually live.
This article is general information, not legal, tax or investment advice.
