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CARF, the Crypto Asset Reporting Framework developed by the OECD, is moving steadily towards implementation, and the next two years will be critical.
Here are the key predictions and trends to watch.
Prediction: 2026 will be the year firms feel the regulatory pressure, with dry runs, schema testing and remediation projects. 2027 will be the first real reporting year for many jurisdictions.
Prediction: Regulators will increasingly scrutinise whether firms have integrated data governance across CRS and CARF rather than treating crypto reporting as a bolt on.
Prediction: Some trust companies, family offices and fund administrators will discover they are in scope indirectly through managed structures or underlying investments in crypto assets.
Prediction: Remediation projects similar to early CRS programmes will reappear, particularly where historic onboarding data is incomplete or inconsistent.
Prediction: Tax authorities will adopt a more analytical approach, using data matching tools to identify discrepancies between CARF, CRS and domestic filings.
Prediction: Cross border groups operating in emerging markets will face staggered implementation timelines and multiple local variations.
- Capture classification data at onboarding
- Link crypto asset activity to controlling persons
- Maintain audit trails
- Produce OECD compliant XML in line with evolving schemas
Prediction: Firms that treat CARF as a strategic data project rather than a compliance tick box will be significantly better positioned for both regulatory inspections and client transparency demands.
In short, CARF is likely to follow the same path as CRS: initial uncertainty, then rapid global convergence. 2026 will be preparation year. 2027 will be proof year.
If you’re unsure how you will manage CARF reporting, please contact us to discuss further.
