Are Your Clients Reporting Crypto?

Trudi Harper 4 min read

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

Some organisations have both obligations, e.g. a custodian bank holding crypto (CRS 2.0) that also runs a trading desk (CARF).

What Does an Reporting Crypto-Asset Service Provider (RCASP) Look Like?

You're likely an RCASP if your business regularly provides:

  • Exchange services (crypto to fiat)
  • Crypto-to-crypto exchanges
  • Transfer execution
  • Custody / safekeeping
  • Issuance services on behalf of an issuer

What Does Reporting Involve?

For each Reportable User, an RCASP reports identity details (name, address, tax residency, TIN), aggregate transaction data across up to eight categories per crypto-asset type, and controlling person information for entity clients, filed in the jurisdiction of the RCASP's strongest nexus (tax residence, incorporation, place of business, or EU authorisation/registration).

Timelines allow some breathing room, but building the data collection, due diligence and XML reporting infrastructure from scratch takes time; starting now beats starting at the deadline.

How Quantios Is Responding

We're building CARF capability directly into eFileConnect (eFC), following the same workflow customers already use for CRS and FATCA. Our roadmap plans to deliver:

  • CARF in eFC: data entry, spreadsheet upload, full validation, and schema-compliant XML v1.5 output, the foundation for all customers
  • Quantios Core data capture and full API integration with eFC: a fully automated pipeline for Quantios Core customers

If you already use eFC for CRS or FATCA, the CARF module will feel immediately familiar.

Do You Have RCASPs to Report?

We're mapping how many customers and prospects have CARF obligations, so we can tailor delivery to your needs. If you think you, or your clients, may be an RCASP, we'd love to hear from you:

  • 📧 Email your account manager if you're an existing customer
  •  📝 Complete our five-minute CARF readiness form  

There's no obligation involved, just an opportunity to talk it through. We'd be glad to hear where you are with CARF, and the earlier we connect, the better we can support you in preparing well ahead of the deadlines.