
The IRS Just Signaled a Major Shift in Digital Asset Tax Compliance, and the Industry Needs to Pay Attention
Nov 7, 2025
A significant IRS update on Form 1099-DA and digital asset reporting just dropped, marking a turning point for crypto tax compliance. The new guidance resets expectations for exchanges, custodians, and digital asset operators alike.
The U.S. government has taken a decisive step in shaping the future of digital asset reporting. This week, the IRS released a new set of FAQs addressing broker reporting obligations for digital assets and the upcoming Form 1099-DA, marking one of the most significant federal updates since Treasury finalized its section 6045 rules.
For exchanges, custodians, wallet providers, stablecoin issuers, NFT platforms, and digital asset infrastructure companies, this is more than a technical update. It’s a clear signal: federal tax compliance for digital assets is entering its next phase.
IRS Releases New Guidance: A Roadmap for Digital Asset Broker Reporting
The new IRS FAQs expand on regulatory expectations and introduce clarifications that affect nearly every corner of the ecosystem, from kiosk operators to custodial brokers to NFT marketplaces.
Here are the major pillars of the update:
1. Clearer Instructions for Transfers, Basis Information, and 1099-DA Completion
The IRS outlines how brokers should treat transfers where customers provide their own acquisition data and offers step-by-step guidance on filling out Form 1099-DA in these scenarios.
Why it matters:
Digital asset movement across multiple platforms has always complicated basis reporting. This guidance gives firms a clearer framework for handling incomplete or “reasonably reliable” information.
2. Expanded Examples on Fee Allocation
The FAQs include new illustrations on how to allocate and report transaction fees in various scenarios.This helps exchanges and brokers standardize fee reporting something the industry has long lacked.
3. Digital Asset Kiosks Now Fully in Scope
The IRS confirms that kiosk operators (e.g., crypto ATMs) qualify as digital asset middlemen and therefore must file Form 1099-DA.This expands the regulatory perimeter and brings more retail-facing businesses under formal reporting requirements.
4. Custodial-Only Providers May Have No Reporting Obligation
A business that only provides custodial services and transfers assets to a third-party exchange without executing the sale generally does not have to file Form 1099-DA.This distinction is critical for wallet providers, vaulting services, and trust-based custodians.
5. Optional Use of “Reasonably Reliable” Acquisition Information
Custodial brokers may use transfer statements or custodial records to determine lot order, though this information generally cannot be used to report basis on Form 1099-DA.
Outcome:
This preserves flexibility while preventing inaccurate basis reporting.
6. Correction to 2025 NFT Reporting Rules
The IRS acknowledged an error in the 2025 Form 1099-DA instructions regarding first-sale NFTs.
Corrected guidance:
Report gross proceeds in Box 11c
Leave Box 1f blank
Eliminating double reporting and aligns the form with intended policy.
7. Stablecoin De-Peg Testing Simplified
To determine whether a Qualifying Stablecoin has de-pegged, a broker only needs to test price deviation on its own platform.This dramatically simplifies compliance, avoiding the need to monitor dozens of external exchanges.
What This Means for Founders, Investors & Digital Asset Operators
This guidance signals a shift from ambiguity to operational expectations.
If you’re a founder:
You’ll need to align your exchange, wallet, or trading infrastructure with new reporting requirements, especially around basis data, stablecoin monitoring, and NFT proceeds.
If you’re an investor:
Expect increased transparency from platforms and more consistent reporting for tax planning and digital asset portfolio management.
If you’re a builder:
The IRS is accelerating the move toward tax-ready digital financial systems. Clearer rules mean you can architect products that are compliant from day one.
What’s Next
Here’s what to watch in the coming months:
Additional IRS FAQs as brokerage and custodial edge cases emerge
Industry comments on Form 1099-DA implementation timelines
Treasury’s continued push to standardize digital asset reporting across platforms
Potential pilot programs on real-time tax reporting for digital assets
🚀 A Turning Point for U.S. Digital Asset Compliance
For years, the digital asset tax landscape has been fragmented, reactive, and difficult to operationalize.
The IRS’ new FAQs mark the beginning of a more unified, enforceable framework one that brings digital asset markets closer to mainstream financial compliance.
If the ecosystem wants to scale, clarity is not just helpful it’s essential.
This latest federal move signals a future where digital assets live inside a mature, standardized regulatory environment. And for innovators, that means new expectations but also new opportunities.
Now is the time to adjust your strategy and systems for the next chapter of U.S. digital asset tax compliance.