Are Your Clients Reporting Crypto?

What Compliance Teams Need to Know About Crypto-Asset Reporting Framework (CARF)

If you work in compliance, tax operations or financial reporting, you've probably heard the acronym CARF. The Crypto-Asset Reporting Framework (CARF) is the Organisation for Economic Co-operation and Development's (OECD) new automatic exchange regime for crypto, and unlike CRS or FATCA, it introduces a genuinely new type of reporting entity: the Reporting Crypto-Asset Service Provider (RCASP).
This post cuts to the one question that matters: do you, or your clients, have CARF obligations?

What Is CARF?

CARF requires crypto-asset service providers (exchanges, brokers, custodians and similar) to report clients' crypto transactions to tax authorities, sitting alongside CRS and FATCA. Most early-adopter jurisdictions are targeting first reports for the 2026 or 2027 tax year, with exchanges between authorities starting 2027–2028.

Unlike CRS's balance-based reporting, CARF reporting is transaction-based: aggregate amounts exchanged, transferred or received per client per crypto-asset type during the year.

Who Has to Report?

The key distinction:

• RCASPs report transactions: what clients bought, sold, transferred and received
• Financial Institutions report balances: year-end crypto holdings, under CRS 2.0