With 48 jurisdictions already collecting detailed crypto transaction data under the Crypto-Asset Reporting Framework (CARF) since January 1, 2026, and the first automatic information exchanges slated for 2027, CARF is shifting from theory to operational reality for many markets. This change signals that crypto will now face the same routine reporting expectations as traditional financial account standards, such as CRS.
CARF implementation is accelerating, but most jurisdictions and institutions are not starting from zero. The real risk is letting CARF strain systems, processes, and controls already supporting CRS and EOIR.
Here’s a practical checklist to assess readiness across all three frameworks:
Legal readiness
- Domestic legislation or directives enacted to require CARF reporting and align with CRS/EOIR mandates.
- Clear guidance defining scope, obligated service providers, reporting timelines, and international exchange expectations.
- Alignment between CARF rules and existing CRS/EOIR legal frameworks.
Data readiness
- Consistent use of identifiers (Tax Identification Numbers, dates of birth, verified residency) across regimes.
- Data quality controls tested under CRS, now extended to crypto-asset-specific fields.
- Validation rules that prevent incomplete or unusable records, including crypto transaction histories with valuation rules.
System readiness
- XML reporting aligned with CARF schema and interoperable with CRS/EOIR reporting tools.
- Capacity for handling corrections, cancellations, and re-filings across both traditional and crypto datasets.
- Clear audit trails for all data changes and submissions to tax authorities.
Governance readiness
- Defined ownership and coordination across tax, compliance, operations, and IT functions.
- Escalation paths for data gaps and reporting issues spanning CRS, CARF, and EOIR.
- Internal controls designed to operate across frameworks, not in isolated silos.
CARF readiness is not a standalone project. It’s a stress test of existing AEOI foundations and extends the reach of automated reporting into a much broader digital ecosystem.
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